Legal Opinion

American Liberty Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided December 13, 1940No. Docket Nos. 98487, 98488Published

1. Petitioner's subsidiary acquired an oil and gas lease by the terms of which and an assignment of the lease by the lessee certain amounts were payable to the lessor and lessee solely out of a portion of the assignee's interest in oil and gas produced from the lease.

Read the full summary

1. Petitioner's subsidiary acquired an oil and gas lease by the terms of which and an assignment of the lease by the lessee certain amounts were payable to the lessor and lessee solely out of a portion of the assignee's interest in oil and gas produced from the lease. Held, that the amounts derived by the assignee from the sale of oil and gas reserved by the lessor and lessee and paid to them are not taxable income of the assignee. 2. The petitioner acquired on May 28, 1932, in a nontaxable reorganization, property in Texas on which it subsequently paid state, county, and independent school…

1Opinion of the Court

AMERICAN LIBERTY OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Liberty Oil Co. v. Commissioner

Docket Nos. 98487, 98488.

United States Board of Tax Appeals

43 B.T.A. 76; 1940 BTA LEXIS 850;

December 13, 1940, Promulgated

1. Petitioner's subsidiary acquired an oil and gas lease by the terms of which and an assignment of the lease by the lessee certain amounts were payable to the lessor and lessee solely out of a portion of the assignee's interest in oil and gas produced from the lease. Held, that the amounts derived by the assignee from the sale of oil and gas…

2Cases cited3 opinions

  1. Columbia Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1940
  2. Texas Coca-Cola Bottling Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  3. American Liberty Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1940

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API