Legal Opinion

Island Creek Coal Co. v. Commissioner

United States Tax Court

Decided November 27, 1964No. Docket No. 91431PublishedCited by 2 opinions

Premiums paid by taxpayer for business interruption fire insurance must be deducted from taxpayer's gross income from mining in computing petitioner's taxable income from the property for percentage depletion purposes.

1Opinion of the Court

OPINION

Drennen, Judge:

Respondent determined deficiencies in petitioner’s income tax for the taxable years 1957 and 1958 in the respective amounts of $406,785.44 and $260,792.69.

The parties have agreed as to the disposition of all issues raised in the pleadings except for one.

The sole issue remaining for decision is whether petitioner, engaged in the business of mining coal, must deduct the amounts of $76,840 and $53,086, representing premiums paid for business interruption fire insurance coverage in the respective years 1957 and 1958, in determining its taxable income from its property to…

2Cases cited21 opinions

  1. Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
  2. F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
  3. F. H. E. Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
  4. Island Creek Coal Co. v. CommissionerUnited States Tax Court · 1958
  5. Montreal Mining Co. v. CommissionerUnited States Tax Court · 1943

16 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Island Creek Coal Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1967
  2. Island Creek Coal Co. v. CommissionerUnited States Tax Court · 1964

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