Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax of the petitioner of $11,458.15 for 1942 and $4,139.58 for 1944. The issues for decision are (1) whether the Hiawatha Mine is one property or several for the purpose of computing a deduction for percentage depletion for 1942; (2) whether the cost, prior to June 1, 1943, of stripping the overburden from a mineral deposit constitutes a capital cost of development recoverable...
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