Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in the petitioner's income tax of $23,789.11 and a 5 per cent addition for negligence (under section 293(a)) of $1,189.46 for 1946 and a deficiency in income tax of $1,584.32 for 1947. The issues requiring decision are:
(1) Whether assessment and collection of the deficiency and addition for 1946 are barred by the statute of limitations;
(2) Whether there was a gain...
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