Adkins v. Commissioner
United States Tax Court
1. Petitioners were drift miners who entered into leases and coal sales agreements giving them the right and obligation to mine certain areas to exhaustion or for 1-year renewable periods. They were not required to make any royalty payments as such (save on de minimis amounts of "employee" coal) but contend that they acquired an economic (depletable) interest in the coal in place through large expenditures of time and risk capital.
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1. Petitioners were drift miners who entered into leases and coal sales agreements giving them the right and obligation to mine certain areas to exhaustion or for 1-year renewable periods. They were not required to make any royalty payments as such (save on de minimis amounts of "employee" coal) but contend that they acquired an economic (depletable) interest in the coal in place through large expenditures of time and risk capital. Held: Such investments were quite similar to those considered by the Supreme Court in Paragon Coal Co. v. Commissioner, 380 U.S. 624. They were all either…
1Opinion of the Court
Leland Adkins and Bernice Adkins, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Adkins v. Commissioner
Docket Nos. 691-66, 692-66, 828-66, 833-66, 2829-66, 2830-66
United States Tax Court
51 T.C. 957; 1969 U.S. Tax Ct. LEXIS 172;
March 12, 1969, Filed
Decisions will be entered under Rule 50 in docket Nos. 691-66, 692-66, 828-66, and 833-66.
Decisions will be entered for respondent in docket Nos. 2829-66 and 2830-66.
1. Petitioners were drift miners who entered into leases and coal sales agreements giving them the right and obligation to mine certain areas to exhaustion or for…
2Cases cited9 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
- Parsons v. SmithSupreme Court of the United States · 1959
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
- Mullins v. CommissionerUnited States Tax Court · 1967
4 more not listed; retrieve them via the Exa API.