This proceeding involves deficiencies in income tax for the calendar year 1951 in the amount of $198,015.65, and for the calendar year 1952 in the amount of $2,558.01. By amended answer, respondent seeks an additional deficiency of $14,139.41 for 1951 and $22,219.63 for 1952.
The issues for decision are: (1) Whether petitioner was entitled to treat its several coal-mining properties as a single property in computing its percentage depletion allowance for 1951 or whether...
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