Memorandum Opinion
TRAIN, Judge:
Respondent determined deficiencies in the petitioner's income tax for the years 1953 and 1954 in the respective amounts of $355.32 and $323.60.
Two issues are presented for our determination:
(1) Whether the period of limitation for assessment and collection of the tax had expired prior to the mailing of the statutory notice of deficiency under the provisions of section 275(a) of the Internal Revenue Code...
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