Legg v. Commissioner
United States Tax Court
Held, petitioners did not have an economic interest in coal mined by them under contracts with the Christian Colliery Company in 1956 and 1957, and accordingly are not entitled to depletion deductions under sections 611 and 613, I.R.C. 1954.
1Opinion of the Court
OPINION.
Bruce, Judge:
Respondent determined deficiencies in the income taxes of the petitioners as follows:
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The two cases were consolidated.
The only issue presented for our determination is whether petitioners, operating as a partnership, are entitled to depletion deductions in the years 1956 and 1957. * All other adjustments determined by respondent in the notices of deficiency have been conceded by petitioners.
The facts have been stipulated and the stipulation, together with the exhibits attached thereto, is incorporated herein by reference.
William M. Legg and Eachel Frances…
2Cases cited9 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
- Parsons v. SmithSupreme Court of the United States · 1959
- Pugh v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Mullins v. CommissionerUnited States Tax Court · 1967
- Merritt v. CommissionerUnited States Tax Court · 1962
- Washburn v. CommissionerUnited States Tax Court · 1965
- Cooper v. CommissionerUnited States Tax Court · 1962
- Whitmer v. CommissionerUnited States Tax Court · 1969
9 more not listed; retrieve them via the Exa API.