McClelland v. Commissioner
United States Tax Court
Ps are partners in S, a coal mining venture. Pursuant to a coal lease, S strip mined coal and loaded it into the trucks of independent contractors. The truckers hauled the coal over the "bench" and over private and public roads to the premises of C, S's purchaser. The truck drivers unloaded the coal into a dumping bin, at the bottom of which was a stationary steel grate.
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Ps are partners in S, a coal mining venture. Pursuant to a coal lease, S strip mined coal and loaded it into the trucks of independent contractors. The truckers hauled the coal over the "bench" and over private and public roads to the premises of C, S's purchaser. The truck drivers unloaded the coal into a dumping bin, at the bottom of which was a stationary steel grate. On virtually each trip, the truck driver used a sledge hammer or pickax to force a few oversize or jammed pieces of coal through the steel grate. Thereafter, C applied to the purchased coal one or more of the coal mining…
1Opinion of the Court
Herbert J. McClelland and Clara H. McClelland, Petitioners v. Commissioner of Internal Revenue, Respondent; Charles J. Chaffin and Jeanette Chaffin, Petitioners v. Commissioner of Internal Revenue, Respondent
McClelland v. Commissioner
Docket Nos. 7629-79, 7630-79
United States Tax Court
83 T.C. 958; 1984 U.S. Tax Ct. LEXIS 2; 83 T.C. No. 52;
December 20, 1984. December 20, 1984, Filed
Decisions of no deficiency and no overpayment will be entered.
Ps are partners in S, a coal mining venture. Pursuant to a coal lease, S strip mined coal and loaded it into the trucks of independent contractors. The…
2Cases cited31 opinions
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- United States v. Paramount Pictures, Inc.Supreme Court of the United States · 1948
- Dixon v. United StatesSupreme Court of the United States · 1965
- Federal Maritime Commission v. Seatrain Lines, Inc.Supreme Court of the United States · 1973
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