Statler v. Commissioner

OPINION.

Morris :

The respondent filed a motion in the above entitled proceeding on June 7, 1932, for judgment on the pleadings, which was called for hearing on September 21,1932, when both parties, by .their *343counsel, were heard in argument upon said motion, and upon the further oral motion of counsel for the respondent that the proceeding be dismissed for want of jurisdiction. The grounds for those motions will be set forth after a brief discussion of the salient facts bearing upon the questions presented thereby.

A deficiency notice was mailed to the petitioner herein on July 21, 1931, setting…