Legal Opinion

Everts v. Commissioner

United States Board of Tax Appeals

Decided October 28, 1938No. Docket Nos. 82995, 83000Published

Where the petitioners, as tenants in common of undivided interests in an oil and gas lease, arranged for the development and management of their property through separate, individual agreements with a common agent whose powers and authority were expressly delegated and fixed in advance by such separate agreements, held, that the petitioners did not constitute associations taxable as corporations.

1Opinion of the Court

C. A. EVERTS ET AL., JAMISON LEASE SYNDICATE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

C. A. EVERTS ET AL., OLLIE COOK LEASE SYNDICATE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Everts v. Commissioner

Docket Nos. 82995, 83000.

United States Board of Tax Appeals

38 B.T.A. 1039; 1938 BTA LEXIS 792;

October 28, 1938, Promulgated

Where the petitioners, as tenants in common of undivided interests in an oil and gas lease, arranged for the development and management of their property through separate, individual agreements with a common agent whose powers and…

2Cases cited1 opinion

  1. Everts v. CommissionerUnited States Board of Tax Appeals · 1938

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