Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined income tax deficiencies of $60,003.74 for 1959, and $62,207.60 for 1960. By stipulations, the parties have disposed of the issues relating to 1959, to which effect will be given under Rule 50. The general issue relating to 1960 is whether in substance petitioner, rather than its subsidiary Bethany, purchased certain coal lands in 1960, so as not to be entitled to a claimed deduction...
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