Citizens Nat'l Bank v. Commissioner
United States Board of Tax Appeals
On March 1, 1913, a partnership of which petitioners were members was, under an oral lease for a term of 15 years, engaged in mining coal from certain land situated in Pennsylvania. The oral lease was, on April 21, 1913, reduced to writing. Under the law of Pennsylvania the members of the partnership were, under the oral lease, only lessees at will.
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On March 1, 1913, a partnership of which petitioners were members was, under an oral lease for a term of 15 years, engaged in mining coal from certain land situated in Pennsylvania. The oral lease was, on April 21, 1913, reduced to writing. Under the law of Pennsylvania the members of the partnership were, under the oral lease, only lessees at will. Under such circumstances, it is held that the oral lease had no fair market value on March 1, 1913, and it is further held that the lease agreement of April 21, 1913, is not subject to depletion or exhaustion deductions, it having cost the…
1Opinion of the Court
CITIZENS NATIONAL BANK, TRUSTEE, ESTATE OF J. A. BAXENDELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GEORGE L. HAWKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
W. W. HAWKINS, EXECUTOR, ESTATE OF JAMES A. HAWKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Citizens Nat'l Bank v. Commissioner
Docket Nos. 10217-10219.
United States Board of Tax Appeals
11 B.T.A. 1315; 1928 BTA LEXIS 3643;
May 11, 1928, Promulgated
On March 1, 1913, a partnership of which petitioners were members was, under an oral lease for a term of 15 years, engaged in mining…
2Cases cited1 opinion
- Citizens Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1928