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POTTS v. COMMISSIONER

Docket No. 2356-87.

90 T.C. 995 (1988)

RAY H. AND PATRICIA POTTS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 16, 1988.

Attorney(s) appearing for the Case

William E. Owen, for the petitioners.

Mark E. Bohe, for the respondent.

OPINION

STERRETT, Chief Judge:*

By notice of deficiency dated. November 12, 1986, respondent determined a deficiency of $1,565.21 in petitioners' Federal income tax for calendar year 1982. After concessions, the sole issue for decision is whether petitioners, who extracted oil and gas in 1981 and reported gross income therefrom in 1982, must use a percentage depletion rate of 18...

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