Memorandum Opinion
SMITH, Judge:
These proceedings involve income tax deficiencies for 1938 and 1939 as follows:
Docket No. Petitioner Year Deficiency 107654 Pilot Royalty Co.. 1938 $ 399.02 107730 Home-Stake Royalty Corp............ 1938 1,450.04 1939 629.80
The question in issue in both proceedings is whether certain oil and gas...
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