MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge.
This case is before the Court for decision without trial. See Rule 122. Petitioners petitioned the Court to redetermine deficiencies in their 1995 and 1996 Federal income taxes. Respondent determined the following deficiencies, all of which stem from respondent's disallowance of depletion deductions claimed by an S corporation named Goodfellow Bros. Inc...
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