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RATIO v. COMMISSIONER

Docket No. 34772.

20 T.C. 785 (1953)

ELVINA RATTO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 7, 1953.

Attorney(s) appearing for the Case

J. Donald Pettus, Esq., for the petitioner.

Dan S. Morrison, Esq., for the respondent.

The respondent determined a deficiency in the income tax of the petitioner for the calendar year 1946 in the amount of $1,000.88. The sole issue is whether the assessment and collection of this deficiency is barred by section 275 of the Internal Revenue Code.1 All the facts were stipulated and are found accordingly.

FINDINGS OF FACT.

At all times during the calendar year 1946 petitioner...

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