Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income and excess profits taxes against the petitioner for the year 1944 in the amounts of $2,291.92 and $25,367.19, respectively. The only issue in controversy is whether the period prescribed by the statute of limitations for assessment and collection of the deficiencies had expired.
Findings of Fact
The facts stipulated are found accordingly.
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