OPINION.
BLACK, Judge:
The Commissioner has determined deficiencies in petitioner's income tax for the year 1939 of $38,005.51 and for the year 1940 of $23,508.48. These deficiencies were due to several adjustments made by the Commissioner to the net income as reported by petitioner on its income tax returns for the respective taxable years. Two of these adjustments were the addition to the net income, as reported by petitioner, of depletion of $81...
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