Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax against petitioner as follows:
Year Deficiency 1947 .................. $14,475.79 1948 .................. 10,137.11
At the trial, petitioner moved for summary judgment on the pleadings as to the year 1947 upon the ground that the statute of limitations had expired. That motion was taken under...
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