Legal Opinion

American Metal Climax, Inc. v. Commissioner

United States Tax Court

Decided November 26, 1963No. Docket No. 58218Published

Petitioner, a company involved in the mining and sale of molybdenum, engaged in a program of exploration and development.

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Petitioner, a company involved in the mining and sale of molybdenum, engaged in a program of exploration and development. Held, a portion of the petitioner's 1942 income arising from the sale of molybdenum constitutes net abnormal income resulting from such exploration and development within the meaning of sections 721(a)(2)(C) and 721(a)(3), I.R.C. 1939, and is allocable to those years prior to 1942, during which the exploration and development work was done, pursuant to section 721(b), I.R.C. 1939.

1Opinion of the Court

American Metal Climax, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

American Metal Climax, Inc. v. Commissioner

Docket No. 58218

United States Tax Court

41 T.C. 292; 1963 U.S. Tax Ct. LEXIS 11;

November 26, 1963, Filed

Decision will be entered under Rule 50.

Petitioner, a company involved in the mining and sale of molybdenum, engaged in a program of exploration and development. Held, a portion of the petitioner's 1942 income arising from the sale of molybdenum constitutes net abnormal income resulting from such exploration and development within the meaning of sections…

2Cases cited9 opinions

  1. Soabar Co. v. CommissionerUnited States Tax Court · 1946
  2. Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
  3. Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
  4. Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1949
  5. Primas Groves, Inc. v. CommissionerUnited States Tax Court · 1950

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