- 13 - 613(b)(7) ("when used, or sold for use"). The legislative history clearly points in the same direction. S. Rept. 1622, supra at 77, 331-332. The House version of this section had included dimension stone and ornamental stone in the enumerated uses, but in the final bill, those were eliminated and, instead, "stone (used or sold for use * * * as dimension stone or ornamental stone)" was included in the list of "all other minerals", thus entitling stone used for those purposes to the higher depletion rate. Id. at 78. Dimension stone means "blocks and slabs of natural stone, subsequently cut to definite shapes and sizes and used or sold for such uses as building stone (excluding rubble), monumental stone, paving blocks, curbing and flagging." Sec. 1.613-2(b)(3), Income Tax Regs. Ornamental stone means "blocks and slabs of natural stone, subsequently cut to definite shapes and sizes and used or sold for use for making ornaments or statues." Id. The enumerated uses are generally construction uses. C. J. Langenfelder & Son, Inc. v. Commissioner, supra at 390. We have interpreted "similar purposes" to include those uses reasonably commercially competitive with the enumerated uses. G. & W. H. Corson, Inc. v. Commissioner, 54 T.C. at 677. In G. & W. H. Corson, Inc. v. Commissioner, supra, the taxpayer mined dolomitic limestone for its use in manufacturing Poz-O-Pac and Corson's masonry cement. Poz-O-Pac was a product composed of hydrated lime, fly ash, an aggregate, and water; itPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011