Legal Opinion

Kern Oil Co. v. Commissioner

United States Tax Court

Decided December 31, 1947No. Docket No. 10148Published

British income taxes of British corporation operating oil-producing properties in United States, held properly deducted in computing 50 per cent of net income from the oil properties for purposes of determining limitation on percentage depletion under Internal Revenue Code, section 114 (b) (3).

1Opinion of the Court

Kern Oil Company, Ltd., Petitioner, v. Commissioner of Internal Revenue, Respondent

Kern Oil Co. v. Commissioner

Docket No. 10148

United States Tax Court

9 T.C. 1204; 1947 U.S. Tax Ct. LEXIS 1;

December 31, 1947, Promulgated

Decision will be entered for the respondent.

British income taxes of British corporation operating oil-producing properties in United States, held properly deducted in computing 50 per cent of net income from the oil properties for purposes of determining limitation on percentage depletion under Internal Revenue Code, section 114 (b) (3).

Melvin D. Wilson, Esq., for the…

2Cases cited4 opinions

  1. Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
  2. F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
  3. Montreal Mining Co. v. CommissionerUnited States Tax Court · 1943
  4. Kern Oil Co. v. CommissionerUnited States Tax Court · 1947

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