Legal Opinion

Royal Collieries Co. v. Commissioner

United States Board of Tax Appeals

Decided January 27, 1925No. Docket No. 233PublishedCited by 1 opinion

The lessee of coal lands is entitled under the Revenue Act of 1916 to the deduction of a reasonable allowance for exhaustion of leasehold based upon March 1, 1913, value or for depletion upon the same basis, either deduction being computed proportionately with the amount of coal mined in the taxable year.

1Opinion of the Court

*370OPINION.

Sternhagen:

The taxpayer on March 1, 1913, was the owner of leaseholds of coal lands. The parties agree that the value thereof on that date was $31,919.75 as found by the Commisisoner. We held in Appeal of The Hotel DeFrance Company, 1 B.T.A., 28, that a leasehold is an asset as to which a deduction may be taken of a reasonable allowance for its exhaustion. In the Appeal of Grosvenor Atterbury, 1 B.T.A., 169, we held that, such a deduction should be based upon the value on March 1, 1913, where acquired prior thereto. Upon the authority of these decisions we hold in this case that this…

2Cases cited3 opinions

  1. Lynch v. Alworth-Stephens Co.Court of Appeals for the Eighth Circuit · 1923
  2. Atterbury v. CommissionerUnited States Board of Tax Appeals · 1924
  3. Hotel de France Co. v. CommissionerUnited States Board of Tax Appeals · 1924

3Cited by1 opinion

  1. Royal Collieries Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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