Legal Opinion
JEFFERSON LAKE SULPHUR COMPANY v. Lambert
District Court, E.D. Louisiana
Decided June 27, 1955No. Civ. A. 4406 and 4407PublishedCited by 5 opinions
1Opinion of the Court
WRIGHT, District Judge.
Plaintiff is suing for refund of income taxes. The question presented is whether the $7,500 quarterly payments made by the taxpayer during the primary term of a sulphur lease are deductible as lease rentals or advance royalties or whether such payments must be capitalized as leasehold costs and recovered through the depletion allowance under § 23 (m) 1 of the Internal Revenue Code of 1939.
On May 28, 1937, Texas Gulf Sulphur Company entered into a mineral lease with Pathfinder Oil Company under which Texas Gulf, in return for mineral rights on certain lands, agreed to…
2Cases cited14 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
9 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Shamrock Oil & Gas Corp. v. CommissionerUnited States Tax Court · 1961
- George A. Lambert and Chester A. Usry v. Jefferson Lake Sulphur Company, United States of America v. Jefferson Lake Sulphur CompanyCourt of Appeals for the Fifth Circuit · 1956
- Murphy Oil Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1964
- Murphy Corp. v. United StatesDistrict Court, W.D. Arkansas · 1964
- Shamrock Oil & Gas Corp. v. CommissionerUnited States Tax Court · 1961