The Commissioner determined deficiencies of $5,317.08 income tax for 1938, and $8,668.24 income tax and $1,777.50 declared value excess-profits tax for 1939. He disallowed a business expense deduction taken in each year for alleged "royalties"; and, in the alternative, the taxpayer contends that such "royalties" should be treated as capital expenditures as the basis of additional depletion deductions.
Findings of Fact
The petitioner, a Michigan corporation...
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