Commissioner of Internal Revenue v. Estate of J. B. Williams, Deceased, Tommy J. Williams and Charles J. Williams, Administrators, and Rosa Williams

DOBIE, Circuit Judge.

This is a petition brought by the Commissioner of Internal Revenue to review a decision of the Tax Court of the-United States, holding that the Commissioner’s assessment of deficiencies in the-taxpayers’ federal income and victory taxes for 1943 and federal income taxes, for 1944 and 1945 is barred by the three-year period of limitations provided by Section 275(a) of the Internal Revenue-Code, 26 U.S.C.A. § 275(a). The only-question that we need consider is whether the Tax Court abused its discretion by denying two motions made by the-Commissioner: (1) to reopen the…