Island Creek Coal Co. v. Commissioner
United States Tax Court
1. During 1951, petitioner mined coal from several economic interests in coal underlying various contiguous tracts of land located within one continuous boundary. In computing its percentage depletion deduction for 1951, petitioner treated all of its coal mines and estates in the coal under development as a single property.
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1. During 1951, petitioner mined coal from several economic interests in coal underlying various contiguous tracts of land located within one continuous boundary. In computing its percentage depletion deduction for 1951, petitioner treated all of its coal mines and estates in the coal under development as a single property. The Commissioner, in his determination of his deficiency for 1951, disallowed the treatment used by petitioner and computed petitioner's percentage depletion deduction by grouping petitioner's mines into three separate "economic interests." By this method the Commissioner…
1Opinion of the Court
This proceeding involves deficiencies in income tax for the calendar year 1951 in the amount of $198,015.65, and for the calendar year 1952 in the amount of $2,558.01. By amended answer, respondent seeks an additional deficiency of $14,139.41 for 1951 and $22,219.63 for 1952.
The issues for decision are: (1) Whether petitioner was entitled to treat its several coal-mining properties as a single property in computing its percentage depletion allowance for 1951 or whether it must use the “separate interests method” as the Commissioner has determined ; (2) whether royalty income received by…
2Cases cited7 opinions
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- Black Mountain Corp. v. CommissionerUnited States Tax Court · 1945
- F. H. E. Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Amherst Coal Co. v. CommissionerUnited States Tax Court · 1948
- Helvering v. Jewel Mining Co.Court of Appeals for the Eighth Circuit · 1942
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