Memorandum Opinion
RAUM, Judge:
In these consolidated cases, the Commissioner determined deficiencies of $35,150.51 and $28,622.37 for petitioners' 1977 and 1978 tax years, respectively. The Government has filed a Motion for Partial Summary Judgment, and after concessions the only issue remaining in dispute in respect of the Government's motion is whether petitioners may deduct in 1977 and 1978 certain amounts paid in those years pursuant to a "Mining Lease...
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