Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined income tax deficiencies against petitioner, for the taxable years 1959 and 1960 in the respective amounts of $227,271.37 and $63,802.02. Petitioner disputes them and claims refunds for each year in the respective amounts of $70,230 and $59,331.
In its petition (paragraphs h through p) the petitioner alleged that, in determining its deduction for depletion of its coal mines...
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