Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This case involves income tax for the calendar year 1945. Deficiency was determined in the amount of $774.23. The whole amount is in dispute. The only question presented for determination is whether the Commissioner erred in allowing depletion on percentage basis under section 114(b) (3) of the Internal Revenue Code, instead of on a basis of value at March 1, 1913, as contended for by the petitioner...
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