TIETJENS, Judge:
The respondent determined a deficiency in income tax in the amount of $15,204.97 for the calendar year 1945. The sole issue is whether sections 1311 to 1314 of the Internal Revenue Code of 1954 are applicable to mitigate the effect of the statute of limitations upon assessment of the deficiency.
The evidence consists of exhibits received at the hearing and the record in Docket No. 37209, which concerned a deficiency determined against...
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