Memorandum Opinion
SMITH, Judge:
The respondent has determined income tax deficiencies of $2,571.49 for 1938 and $1,515.33 for 1939. The only question in issue is whether the petitioner is entitled to loss deductions claimed on account of a number of oil and gas royalties which it determined to be worthless and charged off in its returns for the respective years. Some of the facts have been stipulated.
[The Facts]
Petitioner is a...
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