United States Board of Tax Appeals May 1, 1928, Docket No. 12221 (Floyd v. Commissioner)

*905OPINION.

Trammell:

We will first consider the question as to whether the deficiencies for 1917 and 1919 are barred by the periods of limitation. For 1917 a return was filed on March 31, 1918. The tax was assessed before March 6, 1923. A portion of the assessment was abated but no proceeding for the collection of the tax has been instituted and under the decision in Bowers v.