WINTERS COAL CO. v. COMMISSIONER

Docket No. 1176-69.

57 T.C. 249 (1971)

WINTERS COAL COMPANY, INCORPORATED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 17, 1971.


Attorney(s) appearing for the Case

John Y. Merrell, for the petitioner.

Robert D. Hoffman, for the respondent.


IRWIN, Judge:

Respondent determined the following deficiencies in petitioner's income tax:

Taxable year ended                   Deficiency

March 31, 1965 --------------------  $32,601.27
March 31, 1966 --------------------    9,307.95

After concessions made by respondent, the sole issue for determination is whether petitioner had an economic interest in the coal in place which it mined under a lease from the Alabama...

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