Memorandum Findings of Fact and Opinion
The Commissioner determined income tax deficiencies for the years 1935 and 1936 in the respective amounts of $8,117.99 and $3,659.26, and a deficiency in excess profits tax for the year 1935 in the amount of $2,741.67. Petitioner claims an overpayment of income tax for 1936 in the amount of $1,067.91.
There are three issues: (1) the amount of depreciation, if any, to which petitioner is entitled with respect to improvements...
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