CLARK, Circuit Judge:
The specificity required of a taxpayer in presenting his claim or defense to the Commissioner in his application for refund is the subject of this tax appeal. Because taxpayers have not met the procedural requirements of Int.Rev.Code of 1954, § 7422(a) and Treas.Reg. § 301.6402-2(b) (1) (1955), we hold they may not challenge the Commissioner's deficiency determination.
The Commissioner assessed an income tax deficiency against...
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