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POPE & TALBOT, INC. v. COMMISSIONER

Docket Nos. 5321-71, 5505-71.

60 T.C. 74 (1973)

POPE & TALBOT, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 10, 1973.

Attorney(s) appearing for the Case

William H. Kinsey, for the petitioner.

Gary R. DeFrang, for the respondent.

OPINION

QUEALY, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable year 1966 in the amount of $318,178 and for the taxable year 1967 in the amount of $2,037. The sole question for decision relates to the treatment of the excess so-called "depletion" resulting from an election under section 631(a) in the computation of the alternative tax under section 1201(a).1

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