Nicolazzi v. Commissioner
United States Tax Court
In 1976, petitioner and two other individuals jointly participated in a program whose objective was to acquire noncompetitive "lottery" leases on Federal lands for oil and gas exploration and development. Lottery leases are made available to the public as their terms expire under monthly lotteries administered by the Bureau of Land Management. Persons interested in a particular lease must submit an application and nonrefundable $ 10 filing fee before the filing deadline.
Read the full summary
In 1976, petitioner and two other individuals jointly participated in a program whose objective was to acquire noncompetitive "lottery" leases on Federal lands for oil and gas exploration and development. Lottery leases are made available to the public as their terms expire under monthly lotteries administered by the Bureau of Land Management. Persons interested in a particular lease must submit an application and nonrefundable $ 10 filing fee before the filing deadline. Thereafter, a drawing is held to determine the winning applicant. An applicant may file only one application on each lease,…
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency in petitioners’ 1976 Federal income tax in the amount of $3,735. The deficiency stems from the disallowance of a $10,075 fee paid by Robert Nicolazzi during 1976 to Melbourne Concept, Inc., a company engaged in the business of procuring noncompetitive Federal oil and gas leases on behalf of its clients. The following issues are presented for decision:(1) Whether any portion of the $10,075 fee is deductible under section 212(1) or (2);1(2) Whether any portion of the fee is deductible as a loss on a transaction entered into for profit under…
2Cases cited22 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
- Frank v. CommissionerUnited States Tax Court · 1953
- Smith v. CommissionerUnited States Tax Court · 1982
- Mallinckrodt v. CommissionerUnited States Tax Court · 1943
17 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Fox v. CommissionerUnited States Tax Court · 1984
- United Dairy Farmers, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 2001
- Robert J. Nicolazzi and Judith M. Nicolazzi v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1983
- United Dairy Farmers, Inc. v. United StatesDistrict Court, S.D. Ohio · 2000
- Bingo v. CommissionerUnited States Tax Court · 1991
8 more not listed; retrieve them via the Exa API.