OPINION
LARO, Judge:
The parties submitted this case to the Court without trial. See Rule 122. Petitioner petitioned the Court to redetermine respondent's determination of income tax deficiencies of $399,369 and $753,089 for its taxable years ended September 30, 1991 and 1992, respectively.
We must decide the cost recovery period of certain natural gas recovery systems under the modified accelerated cost recovery system (MACRS). Petitioner...
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