Vinton Petroleum Co. v. Commissioner
United States Board of Tax Appeals
During the taxable years the petitioner operated oil wells on several separate properties. Some of these properties were owned and some were leased. In computing the reasonable allowance for depletion under section 204 of the Revenue Act of 1926, and section 114 of the Revenue Act of 1928, held, the computation should be made with respect to each property separately.
1Opinion of the Court
*553OPINION.
Smith:
The principal issue is whether depletion allowance to be deducted by this taxpayer should be 27% per centum of the combined gross income from the several .properties (as the petitioner contends), or whether the depletion allowance should be computed separately for each property (as the respondent contends). Section 204 (c) (2) of the Revenue Act of 1926, and section 114 (b) (3) of the Revenue Act of 1928 are the same, and are as follows:
In the case of oil and gas wells the allowance for depletion shall be 27% per centum of the gross income from the property during the taxable…
2Cases cited4 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- United States v. Dakota-Montana Oil Co.Supreme Court of the United States · 1933
- P-M-K Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Christy v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by11 opinions
- Helvering v. Jewel Mining Co.Court of Appeals for the Eighth Circuit · 1942
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
- Consumers Natural Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Mascot Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Freeman v. CommissionerUnited States Tax Court · 1967
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