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SKOLSKI v. C. I. R.

No. 15248.

351 F.2d 485 (1965)

Anthony P. SKOLSKI and Kathryne D. Skolski, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided October 22, 1965.

Attorney(s) appearing for the Case

Ralph J. Kmiec, Camden, N. J. (Angelo D. Malandra, Camden, N. J., on the brief), for petitioners.

Robert Waxman, Atty., Dept. of Justice, Tax Div., Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Lucy R. Thornton, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before BIGGS, Chief Judge, and MARIS and STALEY, Circuit Judges.

MARIS, Circuit Judge.

We are asked by the taxpayers in this case to review an order of the Tax Court dismissing for lack of jurisdiction their petition for redetermination of deficiencies in income tax and fraud penalties for the years 1952 through 1959. The notice of the claimed tax deficiencies was sent by the Commissioner to the taxpayers on March 26, 1964. Under Section 6213(a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 6213(a),

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