Holbrook v. Commissioner
United States Tax Court
Held, petitioners are not entitled to a percentage depletion deduction in 1970 with respect to income derived from coal mining under a nonexclusive and nontransferable license which was subject to termination without cause by giving the licensee 10 days' notice.
1Opinion of the Court
Mayo Holbrook and Verna Holbrook, Petitioners v. Commissioner of Internal Revenue, Respondent
Holbrook v. Commissioner
Docket No. 1261-74
United States Tax Court
65 T.C. 415; 1975 U.S. Tax Ct. LEXIS 24;
November 26, 1975, Filed
Decision will be entered for the respondent.
Held, petitioners are not entitled to a percentage depletion deduction in 1970 with respect to income derived from coal mining under a nonexclusive and nontransferable license which was subject to termination without cause by giving the licensee 10 days' notice.
William H. Beck, for the petitioners.
Robert P. Ruwe, for the respondent.
2Cases cited15 opinions
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
- Parsons v. SmithSupreme Court of the United States · 1959
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
- United States v. James C. And Helen M. Stallard, and Dewey H. And Geneva StallardCourt of Appeals for the Fourth Circuit · 1959
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