C. J. Langenfelder & Son, Inc. v. Commissioner
United States Tax Court
Petitioner contracted with the State of Maryland to dredge up specified quantities of oyster shells owned by the State and to redeposit them in designated oyster beds for use as "cultch" (i.e., a surface to which oyster larvae could attach and grow into mature oysters). Maryland paid petitioner a set price of $ 1.10 per cubic yard.
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Petitioner contracted with the State of Maryland to dredge up specified quantities of oyster shells owned by the State and to redeposit them in designated oyster beds for use as "cultch" (i.e., a surface to which oyster larvae could attach and grow into mature oysters). Maryland paid petitioner a set price of $ 1.10 per cubic yard. Concurrently, Maryland agreed, for a royalty of $ 0.90 per cubic yard, that petitioner could dredge an equal quantity of shells for sale to others as cultch and poulty feed. Held, as to shells dredged and redeposited for Maryland, petitioner had no economic…
1Opinion of the Court
C. J. Langenfelder & Son, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
C. J. Langenfelder & Son, Inc. v. Commissioner
Docket No. 8895-75
United States Tax Court
69 T.C. 378; 1977 U.S. Tax Ct. LEXIS 11;
December 6, 1977, Filed
Decision will be entered under Rule 155.
Petitioner contracted with the State of Maryland to dredge up specified quantities of oyster shells owned by the State and to redeposit them in designated oyster beds for use as "cultch" (i.e., a surface to which oyster larvae could attach and grow into mature oysters). Maryland paid petitioner a set price of $ 1.10…
2Cases cited8 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Parsons v. SmithSupreme Court of the United States · 1959
- Matagorda Shell Co. v. CommissionerUnited States Tax Court · 1958
- W. D. Haden Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
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