Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for its taxable year 1966 in the amount of $46,213.61. Petitioner in its petition claims an overpayment of its Federal income tax for its taxable year in the amount of $24,408.36.
The issues for decision are:
1. Whether the statute of limitations barred any assessment of income tax for the year 1966 at the time the notice...
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