The respondent determined deficiencies in petitioner's income tax for 1952 and 1953 in the respective amounts of $11,926.49 and $45,975.41. The deficiencies arose solely from the respondent's action in disallowing certain claimed deductions for depreciation expense and in increasing the gains realized upon certain properties sold, explained in the statutory notice as follows:
It has been determined that you owned an undivided one-half interest as tenant in common...
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