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UTAH ALLOY ORES, INC. v. COMMISSIONER

Docket No. 67258.

33 T.C. 917 (1960)

UTAH ALLOY ORES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 18, 1960.

Attorney(s) appearing for the Case

David A. Johnston, Jr., Esq., for the petitioner.

Hubert E. Kelly, Esq., for the respondent.

TIETJENS, Judge:

The respondent determined deficiencies in income taxes for the calendar years 1952, 1953, and 1954 in the amounts of $546.40, $676.38, and $22,548.19, respectively. There are two issues for decision. These are whether (1) the economic interest in the ore in place is to be shared between petitioner and the miners of the ore for purposes of computing the depletion allowable to petitioner, and (2) whether hauling allowances paid by the purchasers...

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