Occidental Petroleum Corp. v. Commissioner
United States Tax Court
In the allocation of certain expenses among separate mining properties in order to determine the amount of taxable income for the purposes of the 50-percent limitation contained in sec. 613(a), I.R.C. 1954: (1) Petitioner's payments of 40 cents per ton to the United Mine Workers of America Welfare and Retirement Fund constitute direct expenses and should be allocated among the separate mining properties in proportion to tonnage sold.
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In the allocation of certain expenses among separate mining properties in order to determine the amount of taxable income for the purposes of the 50-percent limitation contained in sec. 613(a), I.R.C. 1954: (1) Petitioner's payments of 40 cents per ton to the United Mine Workers of America Welfare and Retirement Fund constitute direct expenses and should be allocated among the separate mining properties in proportion to tonnage sold. (2) Petitioner's selling expenses constitute direct expenses and should be allocated, in proportion to direct expenses among the groups of mines in accordance…
1Opinion of the Court
Occidental Petroleum Corporation, Successor to Island Creek Coal Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Occidental Petroleum Corp. v. Commissioner
Docket Nos. 5147-68, 2013-69
United States Tax Court
55 T.C. 115; 1970 U.S. Tax Ct. LEXIS 43;
October 26, 1970, Filed
Decisions will be entered under Rule 50.
In the allocation of certain expenses among separate mining properties in order to determine the amount of taxable income for the purposes of the 50-percent limitation contained in sec. 613(a), I.R.C. 1954:(1) Petitioner's payments of 40 cents per ton to the United Mine…
2Cases cited19 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
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