OPINION.
OPPER, Judge:
This proceeding involves a deficiency in income tax for the fiscal year ended May 31, 1941, in the amount of $440.33.
The issue is the propriety of respondent's action in deducting a portion of British income and national defense contribution taxes from petitioner's gross income from oil properties, in computing the limitation on percentage depletion pursuant to Internal Revenue Code, section 114 (b) (3).
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