Goldenberg

On October 30, 1939, the Commissioner of Internal Revenue determined that there was a deficiency of $1,727.76 (including a penalty of $345.55) in respect of the income tax of Blanche Goldenberg, hereafter called the taxpayer, for the calendar year 1935 and mailed her a notice of the deficiency. The 90-day period within which she might have filed a petition for a redetermination of the deficiency expired on January 29, 1940. 1 No petition was filed. Accordingly, on April 17, 1940, the deficiency was assessed, and on May 18, 1940, notice was given to and payment was demanded of the taxpayer.

On December 26, 1939, the Commissioner determined that there was a deficiency of $1,347.93 in respect of the taxpayer’s income tax for the calendar year 1936 and mailed her a notice of the deficiency. The 90-day period within which she might have filed a petition for a redetermination of the deficiency expired on March 26, 1940. No petition was filed. Accordingly, on April 19, 1940, the deficiency was assessed, and on May 15, 1940, notice was given to and payment was demanded of the taxpayer.

The taxpayer having neglected to pay them, the aforesaid amounts ($1,727.76 and $1,347.93), with…