Lyons v. Commissioner
United States Tax Court
1. Upon the "pulling" or abandonment of an oil well, petitioner's loss is determined by adjusting its cost basis for depletion allowable, as well as for depreciation allowable. 2. Where petitioner owned a leasehold and has drilled several oil wells thereon, upon the abandonment of one of the wells in the taxable year, leaving other producing wells on the leased tract, he is not entitled to treat the single well so abandoned as a separate property, but he must treat the…
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1. Upon the "pulling" or abandonment of an oil well, petitioner's loss is determined by adjusting its cost basis for depletion allowable, as well as for depreciation allowable. 2. Where petitioner owned a leasehold and has drilled several oil wells thereon, upon the abandonment of one of the wells in the taxable year, leaving other producing wells on the leased tract, he is not entitled to treat the single well so abandoned as a separate property, but he must treat the entire leased parcel as a single mineral property.
1Opinion of the Court
Frank Lyons, Petitioner, v. Commissioner of Internal Revenue, Respondent
Lyons v. Commissioner
Docket No. 11386
United States Tax Court
10 T.C. 634; 1948 U.S. Tax Ct. LEXIS 219;
April 19, 1948, Promulgated
Decision will be entered under Rule 50.
1. Upon the "pulling" or abandonment of an oil well, petitioner's loss is determined by adjusting its cost basis for depletion allowable, as well as for depreciation allowable.
2. Where petitioner owned a leasehold and has drilled several oil wells thereon, upon the abandonment of one of the wells in the taxable year, leaving other producing wells on the…
2Cases cited4 opinions
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
- Berkshire Oil Co. v. CommissionerUnited States Tax Court · 1947
- New Creek Co. v. LedererCourt of Appeals for the Third Circuit · 1924
- Lyons v. CommissionerUnited States Tax Court · 1948