Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies of $5,145.02 and $9,522.12 in the petitioner's income tax for 1947 and 1948, respectively. The issues for determination are the correctness of the respondent's action (1) in determining that the amounts paid by petitioner during the taxable years to a strip mining contractor are to be excluded from the petitioner's gross income from a certain coal mine in determining...
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