The Commissioner has determined a deficiency in income tax for the year 1945 in the amount of $2,514.99.
The determination of the deficiency by the respondent was made after the expiration of the 3-year statute of limitations provided by section 275 (a), Internal Revenue Code.
The issue for decision is whether the adjustments made by the respondent are authorized by section 3801 (b) (2), (3), or (5), Internal Revenue Code.
FINDINGS OF FACT.
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