GREEN, Judge.
On the submission of this case it was contended by counsel for plaintiff that the tax in this case, having been determined under the so-called relief provisions of sections 327 and 328 of the Act of 1918 (40 Stat. 1093), the matter of the amount of the tax was governed by the discretion of the Commissioner in applying these provisions, and that, having once determined the amount, he could not by a second and later determination increase the amount which...
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