Legal Opinion

Cartan v. Commissioner

United States Tax Court

Decided May 16, 1958No. Docket Nos. 56818, 56819, 56821PublishedCited by 20 opinions

1. Petitioners deposited $ 45,000 pursuant to an agreement to prevent wasteful depletion of gas pressure and consequent reduction in the amount of oil recoverable from a producing field.

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1. Petitioners deposited $ 45,000 pursuant to an agreement to prevent wasteful depletion of gas pressure and consequent reduction in the amount of oil recoverable from a producing field. Held, this expenditure should be allocated over a term of years. 2. Held, no portion of the $ 45,000 expended represents the cost of a future interest in minerals. 3. Held, entertainment and travel expenses incurred by petitioner W. T. Sesnon, Jr., are deductible in part. 4. Held, expenses incurred by W. T. Sesnon, Jr., for food and lodging while away from home in connection with the affairs of the American…

1Opinion of the Court

The respondent determined deficiencies in petitioners’ income tax as follows:

Docket Na Petitioner 19$ . 1910

56818 Henry and Barbara Sesnon Cartán_$9, 018. 27 0

56819 W. T., Jr., and Jacqueline K. Sesnon_ 10, 797. 28 $351. 94

56821 Porter and Helen F. Sesnon_ 7, 210. 01 0

There are three issues. First, is the sum of $45,000, expended by the petitioners in the year 1949 to prevent the depletion of gas pressure and consequent reduction in the amount of oil recoverable from a producing field, an expenditure recoverable over a term of years or may it be deducted in the year expended under section 23…

2Cases cited11 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Sutter v. CommissionerUnited States Tax Court · 1953
  3. JONES'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
  4. Alleghany Corp. v. CommissionerUnited States Tax Court · 1957
  5. Baton Coal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931

6 more not listed; retrieve them via the Exa API.

3Cited by20 opinions

  1. Stolk v. CommissionerUnited States Tax Court · 1963
  2. Martin J. And Margaret M. Zaninovich and Vincent M. And Dorothy F. Zaninovich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  3. Zaninovich v. CommissionerUnited States Tax Court · 1978
  4. Blitzer v. United StatesUnited States Court of Claims · 1982
  5. Saltzman v. CommissionerUnited States Tax Court · 1970

15 more not listed; retrieve them via the Exa API.

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