Cottingham v. Commissioner
United States Tax Court
Petitioners entered into an oil- and gas-drilling program under which they agreed to pay $ 13,500 ($ 15,000 in some instances) to Drilling Co. for drilling a well on locations assigned to them under leases held by Transmission Co., an affiliate of the Drilling Co. Petitioners made cash downpayments of $ 2,700 ($ 3,000 in case of a $ 15,000 well) and purportedly borrowed $ 10,800 (or $ 12,000) from Leasing Co., a parent of Transmission Co., to pay Drilling Co. the balances…
Read the full summary
Petitioners entered into an oil- and gas-drilling program under which they agreed to pay $ 13,500 ($ 15,000 in some instances) to Drilling Co. for drilling a well on locations assigned to them under leases held by Transmission Co., an affiliate of the Drilling Co. Petitioners made cash downpayments of $ 2,700 ($ 3,000 in case of a $ 15,000 well) and purportedly borrowed $ 10,800 (or $ 12,000) from Leasing Co., a parent of Transmission Co., to pay Drilling Co. the balances due on the drilling contracts. Payments on the notes were to be paid from amounts Transmission Co. agreed to pay…
1Opinion of the Court
Drennen, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Year Amount Docket No. Petitioner
1969 $12,421.92 5573-72 Lloyd L. Cottingham and Nancy H. Cottingham_
1969 9,252.00 6879-7 2 James M. Benson and Cora Benson_
1966 68.00 807-73 Robert R. Kressin_
1966 69.00 Dorothy A. Kressin_
1969 9,381.00 Robert R. Kressin and Dorothy A. Kressin_
32,523.46 8700-73 Ernest A. Doud and Catherine H. Doud_ ) — i CD 05 00
28,899.14 l — i CD 05 CD
6,295.01 8864-73 Charles F. Wright and Priscilla S. Wright_ h-t CD 05 00
5,034.51 l_a CD 05 CD
5,753.99…
2Cases cited4 opinions
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Haass v. CommissionerUnited States Tax Court · 1970
- Harper Oil Company, a Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1970
- Commissioner v. Estate of DonnellCourt of Appeals for the Fifth Circuit · 1969
3Cited by15 opinions
- Stradlings Bldg. Materials, Inc. v. CommissionerUnited States Tax Court · 1981
- Houston Oil & Minerals Corp. v. CommissionerUnited States Tax Court · 1989
- Gardner v. CommissionerUnited States Tax Court · 1976
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1989
- Puscas v. CommissionerUnited States Tax Court · 1978
10 more not listed; retrieve them via the Exa API.