JONES, Chief Judge.
After paying deficiency taxes and civil tax fraud penalties on his income for the years 1944 through 1947, plaintiff filed claims for refund which were rejected by the Commissioner of Internal Revenue. This action is to recover said fraud penalties and the deficiency tax paid on 1944 income.
There are two issues presented for the court's determination. First: Was the deficiency tax assessed on 1944 income barred...
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