Shaffer v. Commissioner

FINDINGS OF FACT AND OPINION.

Siefkin:

This is a proceeding for the redetermination of a deficiency in income taxes for the year 1917 in the amount of $351,-*299498.14. Hearing was had upon the question of the statute of limitations. Petitioner submitted his case upon that issue upon the pleadings and upon certain evidence introduced by respondent and agreed to by both parties.

Petitioner, a resident of Chicago, Ill., filed his income-tax return for the calendar year 1917 on April 29, 1918, on the form required by the Eevenue Act of 1917. Under date of January 15, 1928, petitioner signed an…