Vest v. Commissioner
United States Tax Court
1. All the stock of V corporation was exchanged for stock of S corporation. At the time, V's sole asset was a lease on oil and gas underlying a portion of petitioners' land. The lease had been acquired upon the organization of V from petitioners through a revocable trust of which petitioners were settlors and beneficiaries. Prior to the organization of V, petitioners and S had unsuccessfully attempted to arrange an exchange of the minerals for a ranch.
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1. All the stock of V corporation was exchanged for stock of S corporation. At the time, V's sole asset was a lease on oil and gas underlying a portion of petitioners' land. The lease had been acquired upon the organization of V from petitioners through a revocable trust of which petitioners were settlors and beneficiaries. Prior to the organization of V, petitioners and S had unsuccessfully attempted to arrange an exchange of the minerals for a ranch. Petitioners had V corporation organized for the purpose of developing the mineral interests and to correct or alleviate certain title problems…
1Opinion of the Court
SteReett, Judge:
Respondent determined the following deficiencies in petitioners’ income taxes for the indicated years:
Year Deficiency
1965_ $762,913.92
1966_1_ 13, 561. 30
1967_ 3, 863. 48
This case presents the Court with four questions for determination:(1) Whether petitioner received certain shares of Standard Oil Co. of California as part of a tax-free corporate reorganization or as a lease bonus or advanced royalty on an oil and gas lease, in 1965.(2) Whether $33,422 received by petitioners during I960, from Standard of California with respect to roads, flowlines, well locations, and tank…
2Cases cited43 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gregory v. HelveringSupreme Court of the United States · 1935
- Palmer v. BenderSupreme Court of the United States · 1932
- United States v. LudeySupreme Court of the United States · 1927
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
38 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Long Term Capital Holdings v. United StatesDistrict Court, D. Connecticut · 2004
- Associated Wholesale Grocers, Inc., and Its Subsidiary, Super Market Developers, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1991
- Merians v. CommissionerUnited States Tax Court · 1973
- Earl Vest and Fay Vest, Petitioners-Appellees-Cross v. Commissioner of Internal Revenue, Respondent-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Yamamoto v. CommissionerUnited States Tax Court · 1980
22 more not listed; retrieve them via the Exa API.