WITHEY, Judge:
The respondent has determined deficiencies in the income and excess profits taxes of the petitioner of $12,501.01 and $9,974.40 for 1952 and 1953, respectively. The single issue is whether the respondent erred in disallowing deductions taken by petitioner for the taxable years 1951 (in computing an unused excess profits credit carryover to 1952), and 1952 and 1953 for percentage depletion of sand and gravel.
FINDINGS OF FACT.
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