Memorandum Opinion
SCOTT, Judge:
On March 10, 1989, respondent filed a motion for summary judgment on the only issue remaining in controversy in this case after several stipulations of settled issues have been filed. The issue raised by the motion for summary judgment is whether the assessment of an increased deficiency claimed by respondent in an amendment to answer filed August 23, 1988, is barred by the period of limitations. The increased deficiency...
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