This proceeding involves a deficiency in income tax for the year 1948 in the amount of $5,653.47.
The contested issue is whether the respondent erred in computing depletion allowable to petitioner for 1948 by treating petitioner's operation as three separate properties within the meaning of section 114 (b) (4) of the Internal Revenue Code, as amended.
A part of the facts have been stipulated and are found accordingly.
FINDINGS OF FACT.
Petitioner...
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