United States Board of Tax Appeals July 26, 1926, Docket No. 3264 (Appeal of Gooding)

*390OPINION.

Aiutndell:

The facts in this appeal are substantially identical with the facts set forth in the Appeal of Mrs. D. Sydney Smith, this day decided, ante, 385. For the reasons set forth in the Smith appeal we are of the opinion that the statute of limitations has run in this case and that the Commissioner is without authority to assess the proposed deficiency.