Respondent determined a deficiency of $7,892.14 in petitioners' income tax for 1948, and a penalty of $1,973.04 for failure to file a timely return.
The questions presented are whether the above deficiency and penalty are barred by the statute of limitations which requires the assessment of income taxes within 3 years after the filing of a return (sec. 275 (a), I. R. C. 1939); and if so, whether petitioners are estopped from claiming the bar of the period of limitations...
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