OPINION
FAY, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable calendar year 1960 in the amount of $10,832.17.
Petitioner has conceded all issues raised by the pleadings except the following: (1) Whether petitioner realized ordinary income of $172,800 subject to the percentage depletion allowance deduction by reason of the payment to her of that amount by Pan American Petroleum Corp.; and (2) whether petitioner...
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