Turbeville v. Commissioner
United States Board of Tax Appeals
1. Use of community labor and funds in negotiating oil and gas leases on separate property of petitioner located in Texas does not impress bonuses and royalties when received with community character. 2. Oral agreement between petitioner and her husband that all income and revenues from her properties should belong one half to each, does not relieve petitioner of tax liability on entire income. 3. Bonuses and royalties received under oil and gas leases in Texas are not rents…
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1. Use of community labor and funds in negotiating oil and gas leases on separate property of petitioner located in Texas does not impress bonuses and royalties when received with community character. 2. Oral agreement between petitioner and her husband that all income and revenues from her properties should belong one half to each, does not relieve petitioner of tax liability on entire income. 3. Bonuses and royalties received under oil and gas leases in Texas are not rents and revenues. 4. Where a woman in Texas executed an oil and gas lease on her land prior to marriage, reserving a…
1Opinion of the Court
OPINION.
GoodRich :
In these proceedings, which upon motion were consolidated, petitioner seeks redeterminations of the following deficiencies in income tax:
1925_$2,376.93
1926_ 57, 653. 05
1927_ 43, 973. 57
1928_ 17, 588.18
1929_ 6, 095. 91
The principal controversy involves amounts received in each year as bonuses and royalties under oil and gas leases granted by petitioner. Respondent determined that these amounts, in their entirety, were the income of and taxable to petitioner. Petitioner contends the bonuses and royalties were community income and should therefore be divided and taxed equally…
2Cases cited24 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Burnet v. HarmelSupreme Court of the United States · 1932
- Poe v. SeabornSupreme Court of the United States · 1930
- Palmer v. BenderSupreme Court of the United States · 1932
- Arnold v. LeonardTexas Supreme Court · 1925
19 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Portland Mfg. Co. v. CommissionerUnited States Tax Court · 1971
- Turbeville v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1936
- Helvering v. Jewel Mining Co.Court of Appeals for the Eighth Circuit · 1942
- Sika Chemical Corp. v. CommissionerUnited States Tax Court · 1975
- Hubble v. CommissionerUnited States Tax Court · 1981
9 more not listed; retrieve them via the Exa API.