WITHEY, Judge:
A deficiency in petitioner's income tax for the taxable year ended June 30, 1956, has been determined by respondent in the amount of $7,821.11. The primary issue is whether respondent has erred in failing to treat as exempt, income derived by petitioner after its adoption of a plan of complete liquidation. Should our decision be that respondent has not so erred, an ancillary issue is whether the assessment of the deficiency is barred by a statute...
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