Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years ended September 30, 1955 and 1956 in the amounts of $41,317.55 and $13,380.53, respectively, and additions to tax under section 6653(b) of the Internal Revenue Code of 1954 of $21,537.96 and $13,254.31, respectively.
The issues for decision are whether assessment and collection of the asserted deficiencies are barred by...
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