Respondent determined a deficiency of $11,206.17 in petitioner's income tax for the year 1946. Petitioner does not challenge the adjustments upon which respondent based his determination of deficiency, but alleges a right to an offsetting increase in depreciation allowance for certain assets beyond the amount claimed in its 1946 return. The sole issue, as presented by petitioner, is:
Whether the transaction in which Standard Coal, Incorporated, acquired the properties...
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