United States Board of Tax Appeals August 31, 1934, Docket No. 72343. (Wobber Bros. v. Commissioner)

lead-opinion

*135OPINION.

Arundell:

The first issue requiring consideration is whether assessment and collection are barred by the statute of limitations. The petitioner’s return for 1925 was filed on March 15, 1926, and the deficiency notice was mailed March 27, 1933, which was after the expiration of the three-year period provided for in section 277 (a) (1) of the Revenue Act of 1926.