Brennen v. Commissioner
United States Tax Court
1. On October 25, 1937, H. C. Frick Coke Co. conveyed to petitioner and his wife coal underlying two tracts of land covering approximately 50 acres. Thereafter, and during the taxable years, the coal was mined. Part of the coal was sold as raw coal, but the slack was processed and sold as coke.
Read the full summary
1. On October 25, 1937, H. C. Frick Coke Co. conveyed to petitioner and his wife coal underlying two tracts of land covering approximately 50 acres. Thereafter, and during the taxable years, the coal was mined. Part of the coal was sold as raw coal, but the slack was processed and sold as coke. The cost of mining the coal, processing the coke, and the sale of both came from a joint bank account of petitioner and his wife, and all of the proceeds from such operation were deposited in such joint account. In the respective taxable years, petitioner and his wife each claimed ownership of one-half…
1Opinion of the Court
OPINION.
Leech, Judge:
Petitioner contests respondent’s action in including in his gross income for the respective taxable years 1940 and 1941, (a) all the gain derived from certain coal mining and coking operations on lands known as Mount Pleasant coal lands; (b) all the dividends from certain shares of stock; and (c) all the interest from certain bonds, payable to bearer. Petitioner and his wife, Gayle P. Brennen, each reported one-half of the gains, dividends, and interest in their individual income tax returns for the respective taxable years.
Petitioner contends that the coal lands from…
2Cases cited22 opinions
- Madden v. Glosztonyi Savings & Trust Co.Supreme Court of Pennsylvania · 1938
- Beihl v. MartinSupreme Court of Pennsylvania · 1912
- Berhalter v. BerhalterSupreme Court of Pennsylvania · 1934
- Gasner v. PierceSupreme Court of Pennsylvania · 1926
- Bramberry's EstateSupreme Court of Pennsylvania · 1893
17 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Morgan v. Finnegan, Collector of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Maiatico v. CommissionerUnited States Tax Court · 1949
- Buder v. CommissionerUnited States Tax Court · 1956
- Bacher v. CommissionerUnited States Tax Court · 1977
- Brennen v. CommissionerUnited States Tax Court · 1945
12 more not listed; retrieve them via the Exa API.