The respondent determined deficiencies in income tax against petitioner for the years 1947 and 1948 of $1,842.34 and $32,802.40, respectively. The question for decision is whether the excess of expenditures by petitioner in respect of its Mine No. 4, over the net receipts from coal sold, is deductible as operating expenses or chargeable to petitioner's capital account under section 29.23 (m)-15 of Regulations 111.
FINDINGS OF FACT.
Petitioner, a corporation...
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