The opinion
*1367 OPINION.
Teussell :
The facts and circumstances involved in both of the taxable years here in controversy and the claims of this petitioner are identical with those set forth in the case of Albertina Baur v. Commissioner, 14 B. T. A. 938, and under authority of that decision we hold that the assessment of the deficiencies for the fiscal years ending January 31, 1919 and 1920, is not barred by the statute of limitations.
Judgment will be entered for the respondent.