Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined a deficiency in income tax for the taxable year 1957, in the amount of $7,811. The issue is whether determination of a deficiency in income tax for 1957 is barred by the 3-year statute of limitations prescribed in section 6501(a), 1954 Code. The respondent determined that one of the petitioners realized additional income of $14,900 in 1957 and, therefore, gross income for 1957...
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