F. H. E. Oil Co. v. Commissioner
United States Board of Tax Appeals
1. Where during the taxable year petitioner received as consideration for drilling an oil well for others, an oil payment contract which it capitalized on its books, but as to which it had received no assignment from the lessee of the fractional oil interest out of which the payment was to be made, petitioner is not the owner of any economic interest in the oil in place, is not entitled to depletion on any payment received under such contract, and should return as a part of…
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1. Where during the taxable year petitioner received as consideration for drilling an oil well for others, an oil payment contract which it capitalized on its books, but as to which it had received no assignment from the lessee of the fractional oil interest out of which the payment was to be made, petitioner is not the owner of any economic interest in the oil in place, is not entitled to depletion on any payment received under such contract, and should return as a part of its gross income all payments received during the taxable year and should deduct as ordinary and necessary business…
1Opinion of the Court
F. H. E. OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
F. H. E. Oil Co. v. Commissioner
Docket No. 92960.
United States Board of Tax Appeals
41 B.T.A. 130; 1940 BTA LEXIS 1231;
January 19, 1940, Promulgated
1. Where during the taxable year petitioner received as consideration for drilling an oil well for others, an oil payment contract which it capitalized on its books, but as to which it had received no assignment from the lessee of the fractional oil interest out of which the payment was to be made, petitioner is not the owner of any economic interest in the oil in…
2Cases cited4 opinions
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Edwards Drilling Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Dearing v. CommissionerUnited States Board of Tax Appeals · 1937
- F. H. E. Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1940