Legal Opinion

Ratliff v. Commissioner

United States Board of Tax Appeals

Decided October 27, 1937No. Docket Nos. 84460, 84461PublishedCited by 1 opinion

DEPLETION. - Where the petitioners were the owners of an oil royalty and sold one-half thereof for cash, they are not entitled to deduction for depletion upon the part so sold.

1Opinion of the Court

OPINION.

Hill:

In these consolidated cases the respondent determined a deficiency of $88.12 in income tax against each petitioner for the year 1933. The petitioners owned a certain royalty interest in oil lands in Texas, one-half of which they sold for $7,121.25 cash. In ! making their returns for income tax they each reported one-half of ¡the $7,121.25 and each claimed a deduction for depletion of 27½ percent, which the respondent disallowed: The correctness of res*763pondent’s ruling is the question for decision. The facts have been stipulated as follows:

It is agreed that the facts in this case…

2Cited by1 opinion

  1. Ratliff v. CommissionerUnited States Board of Tax Appeals · 1937

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