USIBELLI v. COMMISSIONER

Docket Nos. 47797, 47798.

13 T.C.M. 602 (1954)

T. C. Memo. 1954-84

Emil Usibelli and Rose P. Usibelli v. Commissioner. Emil Usibelli v. Commissioner.

United States Tax Court.

Filed June 30, 1954.


Attorney(s) appearing for the Case

A. R. Kehoe, Esq., for the petitioners. Gordon N. Cromwell, Esq., for the respondent.


Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax for 1947 and 1948 of $1,476.69 and $5,648.24. He also determined additions for 1947 of $132.91 and $88.60 under section 294(d)(1) and (2) for failure to file a Declaration of Estimated Tax and for substantial underestimation of Declaration of Estimated Tax. The only issue for decision is whether Emil is entitled to a deduction for percentage depletion in connection...

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