The validity of the contested taxes turns upon the statute of limitations and an alleged waiver thereof by the taxpayer. Notice of the deficiency assessments was mailed to the taxpayer on December 18, 1925. This was too late, unless the time was extended by the waiver, because the five-year period for assessment, provided by section 250(d) of the Revenue Act of 1921 (42 Stat. 265), and reaffirmed by section...
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