Respondent determined deficiencies in petitioner's income tax for the years 1951, 1952, and 1953 in the respective amounts of $32,746.33, $16,356.62, and $23,346.20.
A minor issue relating to the determination for 1953 has been resolved by the parties. The only issue remaining in this litigation is whether petitioner mined "quartzite," which would entitle it to a 15 per cent depletion deduction, or "sand," which would entitle it to a 5 per cent depletion deduction...
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