Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
The petitioner is an Arizona corporation with offices in Oklahoma City, Oklahoma. It filed its income tax return for the calendar year 1939 with the collector of internal revenue for the district of Oklahoma, showing a net loss of $101,372.55. On said return it deducted losses amounting to $43,151.22, arising out of the abandonment in 1939 of two oil and gas leases, which the respondent subsequently...
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