WILES, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the fiscal years ending March 31, 1975, and March 31, 1976, in the amounts of $3,876.36 and $4,478.07, respectively. The issue for decision is whether petitioner held an economic interest in the sand deposits it dredged from the Missouri River within the meaning of section 1.611-1(b)(1), Income Tax Regs.
FINDINGS OF FACT
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