Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax in the amount of $53,065.75 and a deficiency in declared value excess-profits tax of $39,650.32, both for the calendar year 1939. The deficiencies were paid subsequent to the filing of the petition. The only issue for decision is whether the cost of certain water rights which the petitioner acquired on April 26, 1917 was $133,700 as determined by the Commissioner or was...
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