SCOTT, Judge:
Respondent determined a deficiency of $80,661.15 in petitioners' income tax for the calendar year 1964.
The only issue for decision is whether petitioners are entitled to deductions for intangible drilling costs on five gas wells located in Erie County, Pa.
FINDINGS OF FACT
Certain facts have been stipulated and are found accordingly.
Petitioners are husband and wife whose legal residence at the time of the filing...
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