J. SPENCER BELL, Circuit Judge.
Petitioners contend that the Tax Court erred in denying them the percentage depletion deduction on the amounts which they received for their coal. Petitioners are two of a large number of contract mine operators who entered into oral agreements with the Jewell Ridge Coal Corporation [hereinafter Jewell Ridge] sometime prior to 1953 to extract coal from that company's leased property. Their right to the deduction depends upon whether...
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