OPINION
KNUTSON, Chief Justice.
Certiorari to review a decision of the State Tax Court assessing additional taxes against the relator.
The facts are not in dispute. Relator timely filed both Federal and state tax returns for 1958 and 1959. (It has been conceded that the 1958 tax is barred by the running of the statute of limitations so we are concerned here only with the 1959 tax.) On May 18, 1962, the district director of internal revenue notified...
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