Memorandum Opinion
SMITH, Judge:
The respondent has determined deficiencies in petitioner's income tax for 1939 and 1940 in the respective amounts of $826.57 and $298.03. Petitioner protests the determination of all of such deficiencies and in addition claims a refund of $325.57 for 1939. It is alleged that the respondent erred in failing to allow the deduction in 1939 and 1940 of the cost or other basis of certain oil and gas royalties which became worthless...
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