Wynecoop v. Commissioner
United States Tax Court
Petitioner Thomas E. Wynecoop and several of his relatives, enrolled members of the Spokane Indian Tribe, obtained a mineral lease of certain tribal lands and exchanged it for the stock of corporation Midnite. Subsequently, Midnite entered into an agreement with corporation Newmont whereby corporation Dawn was created to mine uranium on the leased lands.
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Petitioner Thomas E. Wynecoop and several of his relatives, enrolled members of the Spokane Indian Tribe, obtained a mineral lease of certain tribal lands and exchanged it for the stock of corporation Midnite. Subsequently, Midnite entered into an agreement with corporation Newmont whereby corporation Dawn was created to mine uranium on the leased lands. Under the agreement, Midnite received 49 percent of Dawn's stock in exchange for the assignment of the mineral lease, and Newmont received the remainder of Dawn's stock in exchange for cash and an agreement to finance the mining venture.…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined deficiencies in the amounts of $126,912.94 and $79,609.48 in petitioners’ Federal income taxes for 1975 and 1976, respectively. Due to a concession by respondent, the only issue for decision is whether certain dividends received by petitioner Thomas E. Wynecoop are exempt from Federal income taxation.
This case was submitted fully stipulated.
Petitioners Thomas E. Wynecoop (hereinafter referred to as petitioner) and Shirley Wynecoop, husband and wife, filed joint Federal income tax returns for 1975 and 1976 with the Internal Revenue Service…
2Cases cited15 opinions
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