TUTTLE, Chief Judge:
These appeals represent an effort by the taxpayer, a Venezuelan air carrier, to test the validity of an assessment made against it for income taxes before payment of the tax. The privilege of having such pre-payment adjudication, of course, normally is found in the right given by the provisions of 26 U.S.C.A. Sections 6212 and 6213. These sections give the taxpayer a period of 90 days (150 days for a non-resident of the United States) after receiving...
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