OPINION.
KERN, Judge:
In this proceeding respondent determined a deficiency in petitioner's income tax for the calendar year 1938 in the amount of $1,302.53. Petitioner's sole assignment of error is that the deficiency is barred by the limitation provisions of section 275 (a) of the Revenue Act of 1938. The notice of deficiency was mailed on December 29, 1947, after the expiration of the period of limitation
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