OPINION OF THE COURT
ADAMS, Circuit Judge.
The sole question presented on this appeal is whether the Tax Court erred in finding that the taxpayers do not have a sufficient "economic interest" in a certain anthracite coal lease in Northumberland County, Pennsylvania to qualify for the depletion deduction allowed by §§ 611 and 613 of the Internal Revenue Code of 1954 ("the Code"), 26 U.S.C. §§ 611, 613.
For the most part, the facts...
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