Court of Appeals for the Second Circuit May 1, 1964, Nos. 64-67, Dockets 28244-28247 (Yagoda v. Commissioner of Internal Revenue)

HAYS, Circuit Judge:

Petitioners seek review of decisions of the Tax Court of the United States, 39 T.C. 170 (1962), holding (I) that the mitigation provisions of Sections 1311-1314 of the Internal Revenue Code of 1954 permit the assessment of certain deficiencies that would otherwise be *487barred by the statute of limitations, and (II) that petitioner Elaine Yagoda (formerly Elaine Drechsler)