Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioner's income tax for fiscal years ended November 30, 1953, 1954 and 1955, in the respective amounts of $9,993.59, $9,183.16 and $3,071.57. Petitioner claims overpayments for fiscal 1954 and 1955 in the respective amounts of $12,097.93 and $6,318.92. The issue still in controversy is whether the depreciation deduction claimed by petitioner for its drilling Rig...
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