United States Board of Tax Appeals April 7, 1925, Docket No. 696 (Appeal of Estate of Wood)

*958OPINION.

James:

In the foregoing appeal no material fact alleged by the taxpayer in the petition was admitted by the Commissioner. The taxpayer was granted three separate opportunities- to appear and present evidence in support of the petition. On each of these three occasions, the taxpayer failed to avail himself of the opportunity so extended.