Respondent determined deficiencies in income tax for the fiscal years ended August 31, 1947, and August 31, 1948, in the amounts of $18,166.74 and $16,529.75, respectively.
The sole issue is whether, in determining the percentage depletion deduction for the taxable years involved, the respondent erred in reducing the petitioner's gross income by the amounts paid by it to certain independent contractors engaged, by written and oral agreements, to extract coal from...
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