Legal Opinion

Hunt Production Co. v. Commissioner

United States Board of Tax Appeals

Decided September 2, 1938No. Docket No. 81341Published

1. Where petitioner sold and assigned an oil and gas lease in consideration for a contract for future payments our of oil if, as, and when produced, held, that respondent erred in including the value of such oil payment contract in petitioner's income as a profit realized in the taxable year. 2. Where petitioner paid an annual franchise tax imposed under the laws of Texas as a tax, held, that respondent erred in disallowing the amount so paid as a deduction, under section…

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1. Where petitioner sold and assigned an oil and gas lease in consideration for a contract for future payments our of oil if, as, and when produced, held, that respondent erred in including the value of such oil payment contract in petitioner's income as a profit realized in the taxable year. 2. Where petitioner paid an annual franchise tax imposed under the laws of Texas as a tax, held, that respondent erred in disallowing the amount so paid as a deduction, under section 23(c) of the Revenue Act of 1932, for taxes paid. 3. Held, that the respondent erred in deducting from petitioner's gross…

1Opinion of the Court

HUNT PRODUCTION COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hunt Production Co. v. Commissioner

Docket No. 81341.

United States Board of Tax Appeals

38 B.T.A. 457; 1938 BTA LEXIS 866;

September 2, 1938, Promulgated

1. Where petitioner sold and assigned an oil and gas lease in consideration for a contract for future payments our of oil if, as, and when produced, held, that respondent erred in including the value of such oil payment contract in petitioner's income as a profit realized in the taxable year.

2. Where petitioner paid an annual franchise tax imposed under the laws…

2Cases cited15 opinions

  1. Palmer v. BenderSupreme Court of the United States · 1932
  2. Thomas v. PerkinsSupreme Court of the United States · 1937
  3. Holeproof Hosiery Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  4. Edwards Drilling Co. v. CommissionerUnited States Board of Tax Appeals · 1937
  5. Dearing v. CommissionerUnited States Board of Tax Appeals · 1937

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