Memorandum Findings of Fact and Opinion
KERN, Judge:
In Docket No. 50108 respondent on May 19, 1953, determined a deficiency in the Federal income tax of petitioner Balanovski for the year 1947 in the amount of $3,187,550.90, with the notation in the statement attached to the notice of deficiency to the effect that "[j]eopardy assessment of $3,028,099.95 of the deficiency determined herein, plus interest as provided by law was made on Lower Manhattan Special...
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