American Liberty Oil Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner's subsidiary acquired an oil and gas lease by the terms of which and an assignment of the lease by the lessee certain amounts were payable to the lessor and lessee solely out of a portion of the assignee's interest in oil and gas produced from the lease.
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1. Petitioner's subsidiary acquired an oil and gas lease by the terms of which and an assignment of the lease by the lessee certain amounts were payable to the lessor and lessee solely out of a portion of the assignee's interest in oil and gas produced from the lease. Held, that the amounts derived by the assignee from the sale of oil and gas reserved by the lessor and lessee and paid to them are not taxable income of the assignee. 2. The petitioner acquired on May 28, 1932, in a nontaxable reorganization, property in Texas on which it subsequently paid state, county, and independent school…
1Opinion of the Court
OPINION.
Disney :
These proceedings were consolidated for hearing and report and involve the redetermination of deficiencies of $54,778.42, $723.55, and $97,929.97 in income tax for the respective years 1932, 1933, and 1934, and a deficiency of $13,735.90 in excess profits tax for the year *781934. All of the facts, except those relating to the deductibility of an item of $120,000, were stipulated. The stipulated facts are incorporated herein by reference as our findings of fact on the issues to which they apply. Separate findings of fact will be made on the issue involving the item of $120,000.
2Cases cited6 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Anderson v. HelveringSupreme Court of the United States · 1940
- Thomas v. PerkinsSupreme Court of the United States · 1937
- Humble Oil & Refining Co. v. StateCourt of Appeals of Texas · 1927
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Commissioner v. American Liberty Oil Co.Court of Appeals for the Fifth Circuit · 1942
- American Liberty Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Boyd v. Comm'rUnited States Tax Court · 1946
- Citizens Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1941