Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency in income tax for the year ended December 31, 1952, in the amount of $112,503.20. The issues remaining for decision are: (1) Whether an amount in excess of 25 percent of the gross income stated in the return was omitted from the return so as to validate consents to extensions of time for assessment executed more than 3 but less than 5 years after the return was filed...
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