OPINION.
RICE, Judge:
This proceeding involves a deficiency in income tax in the amount of $625.50 for the year 1947 determined by the respondent under the provisions of the Internal Revenue Code of 1939. The deficiency notice, which is the basis of this proceeding, was mailed to petitioner more than 3 but less than 5 years after his 1947 income tax return was filed.
The issues to be decided are: (1) Whether the respondent erred in allowing...
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