OPINION.
TIETJENS, Judge:
The respondent determined a deficiency in income tax for the year 1945 in the amount of $8,878.57. This determination was made after the 3-year statute of limitations for assessment, prescribed by section 275 (a) of the Internal Revenue Code, had run. The respondent relies on section 3801 of the Code as his authority for determining the deficiency.
All of the facts have been stipulated and are so found. Those material...
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