LOCKWELL v. COMMISSIONER

Docket No. 24332.

10 T.C.M. 1155 (1951)

Harry L. Lockwell v. Commissioner.

United States Tax Court.

Entered December 12, 1951.


Attorney(s) appearing for the Case

William A. Cruikshank, Jr., Esq., for the petitioner. William P. Flynn, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

This proceeding involves deficiencies in income tax for 1945 and 1946 in the amounts of $323 and $179, respectively.

The issues presented for decision are: (a) whether respondent was barred by the statute of limitations, section 275 (a) of the Internal Revenue Code, from asserting a deficiency against the petitioner for the calendar year 1945; and (b) whether petitioner has established his right to a net long-term...

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