United States Board of Tax Appeals March 2, 1928, Docket No. 17019. (Dunson Mills v. Commissioner)

lead-opinion

*1151OPINION.

Siepkin :

Two issues are before us for decision. The first relates to our jurisdiction; the second to the statute of limitations.

As to jurisdiction, the respondent renews his contention, his motion to that effect having been previously overruled, that the notice and demand dated April 12, 1926, marked “ Second notice and demand,” and the letter of the same date from a