Legal Opinion

Pan-American Life Ins. Co. v. Commissioner

United States Tax Court

Decided August 12, 1955No. Docket Nos. 30070, 35319Published

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

Pan-American Life Insurance Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Pan-American Life Ins. Co. v. Commissioner

Docket Nos. 30070, 35319

United States Tax Court

24 T.C. 901; 1955 U.S. Tax Ct. LEXIS 118; 4 Oil & Gas Rep. 1662;

August 12, 1955, Filed

Decisions will be entered under Rule 50.

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,…

2Cases cited4 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. 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
  3. Great Nat. Life Ins. v. CampbellDistrict Court, N.D. Texas · 1953
  4. Pan-American Life Ins. Co. v. CommissionerUnited States Tax Court · 1955

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