Limitation for reassessment turns on whether an uncommunicated deferment order can exclude time and preserve reopening power

The note concerns whether an uncommunicated deferment order could be relied on to exclude time for reassessment limitation, and whether the assessing authority retained power to reopen the matter within the statutory period. It records competing limitation contentions and part of the court's reasoning on those questions, but the supplied text does not state the final operative determination.

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Issues: Whether the deferment order, which was not communicated to the assessee, could be relied upon to exclude the period of limitation for reassessment, and whether the assessing authority retained power to reopen the matter within the statutory period.

Outcome: The provided text records the competing limitation contentions and part of the court's reasoning, but it does not contain the final operative determination.

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