HALL, Judge:
Respondent determined a $55,920.24 deficiency in petitioner's income tax for its taxable year ending December 31, 1968. Because of concessions made by the parties, the issues for decision are:
1. Whether petitioner had an economic interest in oyster shells which it dredged for the State of Maryland, so as to entitle it to a deduction for depletion under section 611(a).
2. Whether petitioner is entitled...
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