ATKINS, Judge:
The respondent, by notice of deficiency dated February 19, 1964, determined a deficiency in income tax for the taxable year 1957 in the amount of $81,075.05.
The primary issue is whether assessment of any deficiency for 1957 is barred by the statute of limitations which in turn depends upon whether, within the purview of section 6501(e) of the Internal Revenue
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