Memorandum Findings of Fact and Opinion
This is a proceeding to redetermine deficiencies in income and excess profits taxes for the calendar year 1939, in the amounts of $9,693.29 and $3,428.09, respectively. Certain concessions have been made by both parties and will be given effect in the recomputation under Rule 50. Only one issue remains, namely, whether petitioner can deduct from its 1939 income "intangible drilling and development costs," the amount of which...
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