Denise Coal Co. v. Commissioner

1. Denise Coal Company, the owner and lessee of certain coal lands, entered into contracts with various strip miners whereby the strippers were to conduct strip-mining operations on Denise's property. The strippers' compensation was based in part on the market price of the coal; the contracts did not give the strippers an exclusive right to mine the coal until exhaustion but the contracts were only terminable for cause; the strippers used their own equipment; and they built some of the necessary roads and facilities. Held, that in determining Denise's "gross profit from the property" for…