Respondent determined a deficiency of $6,107.71 in petitioner's income tax liability for 1947. Respondent now concedes certain deductions. Petitioner does not contest other disallowances. The remaining issue is whether the petitioner's expenditure of $14,000 for fractional interests in oil and gas leases constitutes optionally expensable intangible drilling cost under section 23(m) of the Internal Revenue Code and Treasury Regulations 111, section 29.23(m)-16. Some of the...
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