Alexander v. Commissioner
United States Tax Court
1. In 1941 petitioners owned stock in CC Corporation which owned oil and gas properties. Petitioners sold their stock for cash and overriding royalty interests in the oil and gas properties. At the time of the sale, the overriding royalty interests had a fair market value.
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1. In 1941 petitioners owned stock in CC Corporation which owned oil and gas properties. Petitioners sold their stock for cash and overriding royalty interests in the oil and gas properties. At the time of the sale, the overriding royalty interests had a fair market value. Held, payments from the overriding royalty interests received by petitioners during the years in issue, 1954, 1955, and 1956, are taxable as ordinary income subject to depletion and not as long-term capital gain. Warren v. United States, 171 F. Supp. 846, certiorari denied 361 U.S. 916, followed. 2. Bad debt losses…
1Opinion of the Court
Glenn E. Alexander and Margaret Y. Alexander, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Alexander v. Commissioner
Docket Nos. 72451, 72452, 72453, 79734, 79735, 79736, 79737
United States Tax Court
34 T.C. 758; 1960 U.S. Tax Ct. LEXIS 102; 12 Oil & Gas Rep. 963;
July 29, 1960, Filed
Decisions will be entered under Rule 50.
1. In 1941 petitioners owned stock in CC Corporation which owned oil and gas properties. Petitioners sold their stock for cash and overriding royalty interests in the oil and gas properties. At the time of the sale, the overriding royalty interests had…
2Cases cited10 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
- Campbell v. CommissionerUnited States Tax Court · 1948
- Towers v. CommissionerUnited States Tax Court · 1955
- Vincent C. Giblin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
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