Memorandum Opinion
WITHEY, Judge:
The respondent determined a deficiency in the decedent's income tax for 1959 in the amount of $3,589.45. The sole issue presented for our decision is whether the issuance of the respondent's statutory notice of deficiency was untimely.
After the filing herein of the petition, answer, and reply, the petitioner filed a motion for judgment on the pleadings on the ground that the respondent is barred by the statute of...
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