Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax of the petitioner for 1948 in the amount of $5,436.58. One question for decision is whether the five-year period of limitation provided by section 275 applies.
Findings of Fact
Charlie and his then wife, Laurita, filed joint income tax returns for the years 1947 and 1948 with the collector of internal...
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