Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in the income tax liability of petitioner's decedent for the year 1921 in the sum of $168,278.34, and also determined that a part of this deficiency was "due to fraud with an intent to evade tax". Petitioner alleges error as to both these determinations and also contends that the determination of any deficiency and assessment of any tax is barred by the statute of limitations and that the...
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