ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years ending July 31, 1955, and July 31, 1956, in the respective amounts of $1,779.55 and $2,704.43.
The issues presented are (1) whether an amount received by a predecessor partnership as insurance proceeds for loss, by fire, of a cotton gin was expended by it in partial replacement of the gin with the result that the depreciation basis of the new gin, to the extent...
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