Estate of Lucas v. Commissioner
United States Tax Court
1. The individual taxpayer, Lucas, leased a coal mine from the Franklins at arm's length for a 25-cent-per-ton royalty. Lucas immediately subleased the mine to Roberts Brothers. Roberts Brothers agreed to pay Lucas a 50-cent-per-ton royalty for "rail coal," all of which was to be delivered to Shawnee, a corporation 75 percent owned by Lucas and 25 percent by his wife, and 25 cents per ton (later 50 cents) for "truck coal," to be delivered to unrelated parties.
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1. The individual taxpayer, Lucas, leased a coal mine from the Franklins at arm's length for a 25-cent-per-ton royalty. Lucas immediately subleased the mine to Roberts Brothers. Roberts Brothers agreed to pay Lucas a 50-cent-per-ton royalty for "rail coal," all of which was to be delivered to Shawnee, a corporation 75 percent owned by Lucas and 25 percent by his wife, and 25 cents per ton (later 50 cents) for "truck coal," to be delivered to unrelated parties. Shawnee paid Roberts Brothers a price sufficient to cover its royalty payments. Lucas also leased a second mine from the Coxes for a…
1Opinion of the Court
Hall, Judge:
Respondent determined deficiencies m petitioners’ income tax as follows:
Docket No. 5688-76 (Lucas)
Year Tax
1969 . $25,260.57
1970 . 26,997.37
1971 . 19,742.04
Docket No. 5707-76 (Shawnee Coal)
F.Y.E. Apr. 30— Tax
1970 . $34,790.79
1971 . 27,145.72
1972 . 72,497.95
Concessions having been made by petitioners, the issues remaining for decision are:(1) Whether certain “royalties” Roberts Brothers and C & S Coal paid Fred F. Lucas per ton of coal mined were in fact dividend payments to Lucas from Shawnee Coal Co., Inc.;(2) Whether part of the amount Shawnee Coal Co., Inc., paid Roberts…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Henry Schwartz Corp. v. CommissionerUnited States Tax Court · 1973
- United States v. Donruss Co.Supreme Court of the United States · 1969
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
16 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Doug-Long, Inc. v. CommissionerUnited States Tax Court · 1979
- Proctor v. CommissionerUnited States Tax Court · 1981
- Estate of Fred F. Lucas, Deceased, Dorothy C. Lucas, and Dorothy C. Lucas, and Shawnee Coal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
- EMI Corp. v. CommissionerUnited States Tax Court · 1985
- Edward B. Wolf, Inc. v. CommissionerUnited States Tax Court · 1987
5 more not listed; retrieve them via the Exa API.