Legal Opinion

Freeman v. Commissioner

United States Tax Court

Decided April 28, 1967No. Docket Nos. 2416-65, 2417-65, 2418-65, 1362-66Published

A partnership composed of petitioners made an agreement with Shell Oil Co. to grant to it certain oil, gas, and sulphur interests by five separate conveyances, two of which were to cover several tracts and the other three to cover one tract each, for which a bonus was to be paid.

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A partnership composed of petitioners made an agreement with Shell Oil Co. to grant to it certain oil, gas, and sulphur interests by five separate conveyances, two of which were to cover several tracts and the other three to cover one tract each, for which a bonus was to be paid. The leases were executed, the bonus paid, and depletion deductions of 27 1/2 percent of the bonus claimed and allowed to the partnership in its computation of its distributable income in years prior to 1962. In 1962 the leases expired as to certain of the tracts without production having been obtained on those…

1Opinion of the Court

Norman Freeman and Ernestine H. Freeman, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Freeman v. Commissioner

Docket Nos. 2416-65, 2417-65, 2418-65, 1362-66

United States Tax Court

48 T.C. 96; 1967 U.S. Tax Ct. LEXIS 110; 26 Oil & Gas Rep. 554;

April 28, 1967, Filed

Decisions will be entered under Rule 50.

A partnership composed of petitioners made an agreement with Shell Oil Co. to grant to it certain oil, gas, and sulphur interests by five separate conveyances, two of which were to cover several tracts and the other three to cover one tract each, for which a bonus was to…

2Cases cited19 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Herring v. CommissionerSupreme Court of the United States · 1934
  3. Douglas v. CommissionerSupreme Court of the United States · 1944
  4. Berkshire Oil Co. v. CommissionerUnited States Tax Court · 1947
  5. Sneed v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941

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