Pan-American Life Ins. Co. v. Commissioner
United States Tax Court
Royalties on oil and gas leases held not "rents" within the meaning of section 201 (c) (1), Internal Revenue Code of 1939, and hence not includible in the income of petitioner, a life insurance company. Campbell v. Great National Life Insurance Company, (C. A. 5, 1955) 219 F. 2d 693, followed.
1Opinion of the Court
OPINION.
Offer, Judge:
For the years 1942 through 1946 respondent determined deficiencies in income tax in the respective amounts of $4,353.98, $4,264.01, $16,719.93, $13,221.25, and $12,753. The sole litigated issue is whether royalties received under oil and gas leases are income to petitioner, a life insurance company, and whether, if so, depletion is an allowable deduction, under the restricted provisions of section 201 (c), Internal Revenue Code of 1939.
All of the facts have been stipulated. They are hereby found in accordance with the stipulation, which, as far as here material reads as…
2Cases cited3 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance CompanyCourt of Appeals for the Second Circuit · 1955
- Great Nat. Life Ins. v. CampbellDistrict Court, N.D. Texas · 1953
3Cited by3 opinions
- General American Life Ins. Co. v. CommissionerUnited States Tax Court · 1956
- General American Life Ins. Co. v. CommissionerUnited States Tax Court · 1956
- Pan-American Life Ins. Co. v. CommissionerUnited States Tax Court · 1955