Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1962 and 1963 in the amounts of $73,023.47 and $50,342.21, respectively.
The only issue in this case is whether petitioner is entitled to deduct the portion of the depreciation on transportation equipment used both for maintaining existing and building new facilities attributable to construction of the...
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