Memorandum Findings of Fact and Opinion
OPPER, Judge:
Of a deficiency determined in petitioner's 1958 income tax of $9,347.35, $8,760.00 is in controversy. The sole issue is whether petitioner is entitled to deduct percentage depletion on rock, sand, and gravel which it removed from property that had already been dredge-mined for gold. Certain concessions have been made by petitioner.
Findings of Fact
Petitioner, a California corporation...
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