Legal Opinion

Watnick v. Commissioner

United States Tax Court

Decided March 9, 1988No. Docket No. 26051-86Published

In a lottery, petitioner acquired from the U.S. Department of Interior a mineral lease on 311.53 acres of land in Wyoming which was not within any known geologic structure of a producing oil or gas field.

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In a lottery, petitioner acquired from the U.S. Department of Interior a mineral lease on 311.53 acres of land in Wyoming which was not within any known geologic structure of a producing oil or gas field. He transferred a one-third interest in the lease to Melbourne and on Oct. 3, 1982, he and Melbourne assigned the lease to Exxon in consideration of a cash payment, retaining a purported production payment of $ 10,000 per acre payable out of 5 percent of any oil or gas marketed from the lease. Held, based on the record, there was no reasonable prospect or expectation that the lease would…

1Opinion of the Court

Sheldon S. Watnick and Elizabeth Fay Taylor-Watnick and Susan Watnick, Petitioners v. Commissioner of Internal Revenue, Respondent

Watnick v. Commissioner

Docket No. 26051-86

United States Tax Court

90 T.C. 326; 1988 U.S. Tax Ct. LEXIS 26; 90 T.C. No. 26; 98 Oil & Gas Rep. 658;

March 9, 1988; As amended March 9, 1988 March 9, 1988, Filed

Decision will be entered under Rule 155.

In a lottery, petitioner acquired from the U.S. Department of Interior a mineral lease on 311.53 acres of land in Wyoming which was not within any known geologic structure of a producing oil or gas field. He transferred a…

2Cases cited28 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Burnet v. HarmelSupreme Court of the United States · 1932
  3. Palmer v. BenderSupreme Court of the United States · 1932
  4. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  5. Victory Carriers, Inc. v. LawSupreme Court of the United States · 1971

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