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RAMEY v. COMMISSIONER

Docket No. 5357-64.

47 T.C. 363 (1967)

LESTA RAMEY AND ALKA RAMEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 4, 1967.

Attorney(s) appearing for the Case

John A. Dunkel, for the petitioners.

Conley G. Wilkerson, for the respondent.

FAY, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1960 and 1961 in the amounts of $2,559.47 and $865.84, respectively.

The only issue for decision is whether petitioners are entitled to deductions for percentage depletion on coal mined from a certain tract of land known as the Blood property during the calendar years 1960 and 1961.

FINDINGS OF FACT

Petitioners Lesta (hereinafter referred to as...

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