Legal Opinion

Camp Wolters Land Co. v. Commissioner

United States Tax Court

Decided June 28, 1945No. Docket No. 4709Published

1. Petitioner, a corporation organized under the laws of the State of Texas, held to have come into existence as a separate taxable entity on the date of the filing of its charter (Apr. 25, 1941), and in the application of section 711 (a) (3), I. R. C., the period to be considered is the period from that date to December 31, 1941. 2. The Commissioner's determination in connection with lease rentals for the period March 1 to April 25, 1941, received by petitioner and reported…

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1. Petitioner, a corporation organized under the laws of the State of Texas, held to have come into existence as a separate taxable entity on the date of the filing of its charter (Apr. 25, 1941), and in the application of section 711 (a) (3), I. R. C., the period to be considered is the period from that date to December 31, 1941. 2. The Commissioner's determination in connection with lease rentals for the period March 1 to April 25, 1941, received by petitioner and reported by it in its income, held, sustained where the issue pertaining thereto was not raised by the pleadings and was…

1Opinion of the Court

Camp Wolters Land Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Camp Wolters Land Co. v. Commissioner

Docket No. 4709

United States Tax Court

5 T.C. 336; 1945 U.S. Tax Ct. LEXIS 134;

June 28, 1945, Promulgated

Decision will be entered under Rule 50.

1. Petitioner, a corporation organized under the laws of the State of Texas, held to have come into existence as a separate taxable entity on the date of the filing of its charter (Apr. 25, 1941), and in the application of section 711 (a) (3), I. R. C., the period to be considered is the period from that date to December 31, 1941.

2.…

Also in this document: Dissent.

2Cases cited14 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
  3. Weatherford, Mineral Wells & Northwestern Railway Co. v. GrangerTexas Supreme Court · 1894
  4. William Cameron & Co. v. TrueheartCourt of Appeals of Texas · 1914
  5. Burford Oil Co. v. CommissionerUnited States Tax Court · 1945

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