OPINION
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1983 in the amount of $16,976,702. The parties have settled all of the adjustments to petitioner's tax liability contained in the statutory notice of deficiency except one. The sole issue to be decided is whether petitioner must, under the provisions of section 1254 of the Internal Revenue Code, "recapture" intangible drilling and...
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