OPINION
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1956 in the amount of $6,452.19, and in his answer claimed an increased deficiency in the amount of $357.38 making a total deficiency in controversy of $6,809.57.
The issue for decision is whether at the date of issuance of the notice of deficiency, the period within which respondent might determine a deficiency was open under the provisions...
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