Appeal of Emmons Coal Mining Co.

*1303OPINION.

The above expenditures were proper charges to capital account and not deductible as ordinary and necessary expenses. Appeal of Winifrede Goal Co., 1 B. T. A. 566; Appeal of Union Collienes Co., 3 B. T. A. 540; Appeal of Kirk Coal Co., 3 B. T. A. 755.

The deficiency is $3,64-9.57 for the calendar year 19W. Order will 5e entered accordingly.