WIDENER, Circuit Judge:
Taxpayer appeals the decision of the Tax Court, 82 T.C. 546, in which the court determined that pursuant to a notice of deficiency sent to taxpayer in 1979, within six years of his 1972 tax return filing, an assessment of deficiency for 1972 was not barred by the general three-year statute of limitations because taxpayer omitted from gross income an amount properly includible therein which was in excess of 25 percent of the amount of gross...
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