Rocky Mountain Dev. Co. v. Commissioner
United States Board of Tax Appeals
1. Where petitioner, in exchange for oil well equipment, acquired certain oil payment contracts for stipulated amounts to be paid out of the proceeds from oil if, as, and when produced from the properties upon which the exchanged equipment was installed, and the petitioner's right to receive such future payments and thus recoup its cost and realize taxable profits, if any, was wholly contingent upon the indeterminable happening of future events, held, that petitioner is…
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1. Where petitioner, in exchange for oil well equipment, acquired certain oil payment contracts for stipulated amounts to be paid out of the proceeds from oil if, as, and when produced from the properties upon which the exchanged equipment was installed, and the petitioner's right to receive such future payments and thus recoup its cost and realize taxable profits, if any, was wholly contingent upon the indeterminable happening of future events, held, that petitioner is entitled to apply the payments actually received during the taxable year on each contract, respectively, in recoupment of…
1Opinion of the Court
*1304OPINION.
Txson:
For the calendar year 1933 the respondent determined a deficiency of $1,374.23 in income tax and of $215.09 in excess profits tax.
The errors assigned by petitioner are:(1) That respondent erred in his method of determining petitioner’s taxable income received from certain “oil payments.”(2) That respondent erred in failing to allow depletion with respect to sums received from “oil payments.”(3) That respondent erred in determining that petitioner was liable for any excess profits tax.
The respondent admits the petitioner’s first assignment of error, denies petitioner’s second and…
2Cases cited4 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
- Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938
- Helvering v. O'DONNELLSupreme Court of the United States · 1938
3Cited by7 opinions
- United States v. YergerDistrict Court, E.D. Pennsylvania · 1944
- Boudreau v. CommissionerUnited States Board of Tax Appeals · 1941
- Kimbell v. CommissionerUnited States Board of Tax Appeals · 1940
- Rocky Mountain Dev. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Warren v. United StatesUnited States Court of Claims · 1959
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