Memorandum Findings of Fact and Opinion
OPPER, Judge:
For the year 1946 respondent determined deficiencies in income tax of $178,763.69 and in additions to tax under sections 293(b), 294(d)(1)(A), and 294(d)(2), I. R. C. 1939, of $89,381.85, $18,258.08 and $10,924.84, respectively. Respondent has made a jeopardy assessment.
The issues to be decided are: (1) Whether assessment of the deficiencies is barred by the statute of limitations and if not...
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