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MILLER v. COMMISSIONER

Docket No. 45894.

13 T.C.M. 809 (1954)

T. C. Memo. 1954-129

Robert H. Miller and Doris K. Miller v. Commissioner.

United States Tax Court.

Filed August 17, 1954.

Attorney(s) appearing for the Case

Erwin Lampe, Esq., and Max B. Lewis, Esq., for the petitioners. Earl C. Crouter, Esq., and Francis P. Campbell, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The respondent determined deficiencies of $983.72 and $9,454.06 in the income tax of the petitioners for 1948 and 1949, respectively. The only issues for determination are (1) whether first year payments made on noncompetitive oil and gas leases issued by the United States were deductible as rentals, and (2) whether filing fees paid in connection with applications made for noncompetitive oil and gas...

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