Guanacevi Mining Co. v. Commissioner
United States Board of Tax Appeals
1. Expenditures for tunnels, equipment, and a mill necessary to extract ore profitably from a mine previously worked by primitive methods, held, a capital investment recoverable through depletion allowances and not a deductible operating expense. 2. Interest paid on borrowings for the development of a mine, held, to reduce the net income of the property for purposes of computing the deduction for percentage depletion.
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1. Expenditures for tunnels, equipment, and a mill necessary to extract ore profitably from a mine previously worked by primitive methods, held, a capital investment recoverable through depletion allowances and not a deductible operating expense. 2. Interest paid on borrowings for the development of a mine, held, to reduce the net income of the property for purposes of computing the deduction for percentage depletion. Mirabel Quicksilver Co.,41 B.T.A. 401, followed. 3. No credit under section 26(c)(1), Revenue Act of 1936, is available to a taxpayer because the payment of a dividend was…
1Opinion of the Court
GUANACEVI MINING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Guanacevi Mining Co. v. Commissioner
Docket Nos. 99764, 101902, 102712.
United States Board of Tax Appeals
43 B.T.A. 517; 1941 BTA LEXIS 1492;
February 4, 1941, Promulgated
1. Expenditures for tunnels, equipment, and a mill necessary to extract ore profitably from a mine previously worked by primitive methods, held, a capital investment recoverable through depletion allowances and not a deductible operating expense.
2. Interest paid on borrowings for the development of a mine, held, to reduce the net income of the…
2Cases cited4 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Crane-Johnson Co. v. HelveringSupreme Court of the United States · 1940
- Guanacevi Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Mirabel Quicksilver Co. v. CommissionerUnited States Board of Tax Appeals · 1940