Legal Opinion

Waggoner v. Commissioner

United States Board of Tax Appeals

Decided January 26, 1927No. Docket Nos. 5880, 5881Published

1. A taxpayer lessor who keeps his books and renders his returns upon a cash receipts and disbursements basis, which method in the circumstances of this proceeding is held clearly to reflect income, is entitled to a reasonable allowance for depletion only upon the amount of royalties received. 2. In the circumstances of this proceeding it is held that a sale of an oil and gas royalty interest was consummated in the calendar year 1919, and the Commissioner's determination…

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1. A taxpayer lessor who keeps his books and renders his returns upon a cash receipts and disbursements basis, which method in the circumstances of this proceeding is held clearly to reflect income, is entitled to a reasonable allowance for depletion only upon the amount of royalties received. 2. In the circumstances of this proceeding it is held that a sale of an oil and gas royalty interest was consummated in the calendar year 1919, and the Commissioner's determination that the profit resulting therefrom was taxable in that year is approved.

1Opinion of the Court

APPEAL OF R. M. WAGGONER.

APPEAL OF ADA WAGGONER.

Waggoner v. Commissioner

Docket Nos. 5880, 5881.

United States Board of Tax Appeals

5 B.T.A. 1191; 1927 BTA LEXIS 3654;

January 26, 1927, Promulgated

1. A taxpayer lessor who keeps his books and renders his returns upon a cash receipts and disbursements basis, which method in the circumstances of this proceeding is held clearly to reflect income, is entitled to a reasonable allowance for depletion only upon the amount of royalties received.

2. In the circumstances of this proceeding it is held that a sale of an oil and gas royalty interest was…

2Cases cited1 opinion

  1. Appeal of WaggonerUnited States Board of Tax Appeals · 1927

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