Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined deficiencies in income tax for 1947 and 1948 of $1,476.69 and $5,648.24. He also determined additions for 1947 of $132.91 and $88.60 under section 294(d)(1) and (2) for failure to file a Declaration of Estimated Tax and for substantial underestimation of Declaration of Estimated Tax. The only issue for decision is whether Emil is entitled to a deduction for percentage depletion in connection...
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