Memorandum Opinion
WITHEY, Judge:
A deficiency has been determined by the respondent in petitioner's income tax for 1950 in the amount of $12,356.34. The only issue for determination is whether after the expiration of the statutory period of limitations provided under section 275 of the Internal Revenue Code of 1939, respondent by application of sections 1311-1314, inclusive, of the Internal Revenue Code of 1954 may by his deficiency determination correct...
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