Belridge Oil Co. v. Commissioner

*816OPINION.

MokRis :

While the respondent’s deficiency notice covers deficiencies for the years 1921 to 1923, inclusive, and while the petition states that the taxes “ in controversy are income and profits taxes for the years 1921 to 1923, inclusive,” the said petition, as amended, fails to allege error on the part of the respondent in other than the year 1921, and, since the evidence adduced at the hearing was confined to the issues pertaining exclusively to the year 1921, the respondent’s motion, made at the hearing, to affirm his determination of the deficiencies for 1922 and 1923 is granted.

Our…