OPINION.
RICE, Judge:
The Commissioner determined deficiencies in income tax for the years 1944 and 1945 in the amounts of $6,729.51 and $7,975.12, respectively.
The sole issue is whether petitioner is entitled to amortize intangible drilling and development costs of three gas wells under section 124 of the Code or whether such costs are recoverable as depletion under section 23 (m) of the Code. All of the facts were stipulated.
The...
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