Legal Opinion

Cockburn v. Commissioner

United States Tax Court

Decided April 13, 1951No. Docket Nos. 27421, 27422Published

Petitioners were the owners of a certain oil and gas lease in Texas on which had been developed 19 producing oil wells and one gas well. In 1942, petitioners assigned their interests in the property to another for a cash consideration and, in addition thereto, an overriding royalty of 3/32nds of all oil and gas produced on the lease and a contingent oil payment of $ 112,500 out of oil to be produced on the lease.

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Petitioners were the owners of a certain oil and gas lease in Texas on which had been developed 19 producing oil wells and one gas well. In 1942, petitioners assigned their interests in the property to another for a cash consideration and, in addition thereto, an overriding royalty of 3/32nds of all oil and gas produced on the lease and a contingent oil payment of $ 112,500 out of oil to be produced on the lease. Of the cash consideration received, $ 95,000 was allocated to the sale price of the physical equipment on the lease and is not in controversy. The Commissioner in his determination…

1Opinion of the Court

Dorothy Cockburn, Petitioner, v. Commissioner of Internal Revenue, Respondent. H. C. Cockburn, Petitioner, v. Commissioner of Internal Revenue, Respondent

Cockburn v. Commissioner

Docket Nos. 27421, 27422

United States Tax Court

16 T.C. 775; 1951 U.S. Tax Ct. LEXIS 227;

April 13, 1951, Promulgated

Decisions will be entered under Rule 50.

Petitioners were the owners of a certain oil and gas lease in Texas on which had been developed 19 producing oil wells and one gas well. In 1942, petitioners assigned their interests in the property to another for a cash consideration and, in addition thereto, an…

2Cases cited1 opinion

  1. Cockburn v. CommissionerUnited States Tax Court · 1951

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