Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in the income tax of the petitioners for the years 1953 and 1954 in the amounts of $6,262.26 and $783.90, respectively.
The single question involved is whether petitioner Norman E. Clifton had an economic interest in the coal which he mined under contracts with Jewell Ridge Coal Corporation during the taxable years 1953 and 1954 so as to be entitled to deductions...
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