Memorandum Opinion
ARNOLD, J.:
This proceeding involves income tax deficiencies for 1937, 1938 and 1939 in the respective amounts of $21,428.28, $15,571.32 and $12,958.74, and an excess profits tax deficiency for 1937 in the amount of $212.87. Petitioner alleges that it has overpaid its income taxes for the respective taxable years by the sum of $3,035.12, $3,382.96 and $2,045.30. The issue to be decided is the amount of percentage depletion, if any, to...
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