T.C. Memo. 1997-51
UNITED STATES TAX COURT
BRYAN ROCK PRODUCTS, INC. AND SUBSIDIARY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23230-94. Filed January 28, 1997.
Walter A. Pickhardt, for petitioner.
John C. Schmittdiel, for respondent.
MEMORANDUM OPINION
TANNENWALD, Judge: Respondent determined deficiencies in
petitioner's Federal income taxes for the taxable years ending
November 30, 1989, and November 30, 1990, in the amounts of
$23,926 and $25,622, respectively. The sole issue for decision
is whether petitioner is entitled to a 14-percent depletion
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