Ramey v. Commissioner
United States Tax Court
Held: The agreement between Jisco and the petitioners is not substantively different from the agreements involved in Parsons v. Smith, 359 U.S. 215 (1959), and Paragon Coal Co. v. Commissioner, 380 U.S. 624 (1965). The petitioners herein did not therefore possess an economic interest in the subject coal in place so as to allow a deduction for depletion.
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years 1960 and 1961 in the amounts of $2,559.47 and $865.84, respectively.
The only issue for decision is whether petitioners are entitled to deductions for percentage depletion on coal mined from a certain tract of land known as the Rlood property during the calendar years 1960 and 1961.
FINDINGS OF FACT
Petitioners Lesta (hereinafter referred to as petitioner or Ramey) and Alka Ramey filed joint Federal income tax returns for the calendar years 1960 and 1961 with the district director of internal revenue,…
2Cases cited4 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Parsons v. SmithSupreme Court of the United States · 1959
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
3Cited by15 opinions
- Mullins v. CommissionerUnited States Tax Court · 1967
- Victory Sand & Concrete, Inc. v. CommissionerUnited States Tax Court · 1974
- Holbrook v. CommissionerUnited States Tax Court · 1975
- Missouri River Sand Co. v. CommissionerUnited States Tax Court · 1984
- Adkins v. CommissionerUnited States Tax Court · 1969
10 more not listed; retrieve them via the Exa API.