Strutzel v. Commissioner
United States Tax Court
Petitioners transferred their interests in unpatented mining claims under a document entitled "Mining Lease and Option to Purchase."
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Petitioners transferred their interests in unpatented mining claims under a document entitled "Mining Lease and Option to Purchase." The transfer was for a term of approximately 10 years and the transferee was given the option to purchase at any time during the term of the lease for $ 500,000. Petitioners were to receive fixed annual payments in increasing amounts, and production royalties to be offset against the fixed annual payments, with both to be applied against the purchase price if the option was exercised. The fixed annual payments totaled $ 500,000 if paid throughout the term of the…
1Opinion of the Court
Deennen, Judge:*
Respondent determined deficiencies in Federal income taxes of petitioners for the designated years in the following amounts:
Docket No. Petitioner Year Deficiency 6449-69-.. Joseph J. Strutzel, Jr., and Justine W. Strutzel. 6450-69_Mark T. Miller and Louise D. Miller_ fl9G6 .<1967 [1968 (1966 ' (1967 $1,408.00 1,200. 00 1,573.86 854.14 753.37
The cases were consolidated on a joint motion of all the parties because of their common issues of law and fact. Prior to trial petitioners Mark and Louise Miller consented to a settlement of one issue, and petitioners Joseph and Justine…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Anderson v. HelveringSupreme Court of the United States · 1940
9 more not listed; retrieve them via the Exa API.
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