Legal Opinion

Carborundum Co. v. Commissioner

United States Tax Court

Decided April 26, 1978No. Docket Nos. 7289-74, 2338-75, 2339-75PublishedCited by 4 opinions

Mining process of the mineral "Seneca Standard" tripoli determined.

1Opinion of the Court

Wiles, Judge:

Respondent determined the following deficiencies in petitioner’s Federal income taxes:

Year Deficiency Year Deficiency

1963.$39,250.00 1966.$57,861.10

1964. 43,986.00 1967.57,350.31

1965. 42,753.00 1968.54,991.38

Various issues have been settled and one issue has been severed for independent briefing and opinion. The only issue currently presented for our decision is what steps in processing the mineral “Seneca Standard” tripoli are mining processes for purposes of calculating petitioner’s allowable depletion deduction under section 611.2

FINDINGS OF FACT

Some of the facts have been…

2Cases cited11 opinions

  1. Golsen v. CommissionerUnited States Tax Court · 1970
  2. Standard Lime and Cement Company (Formerly Known as the Standard Lime and Stone Company) v. The United StatesUnited States Court of Claims · 1964
  3. Robert A. Riddell, District Director of Internal Fevenue, Former Collector of Internal Revenue v. Victorville Lime Rock Co., a CorporationCourt of Appeals for the Ninth Circuit · 1961
  4. United States v. California Portland Cement Co.Court of Appeals for the Ninth Circuit · 1969
  5. Virginia Greenstone Company, Incorporated v. United StatesCourt of Appeals for the Fourth Circuit · 1962

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3Cited by4 opinions

  1. Ideal Basic Industries, Inc. v. CommissionerUnited States Tax Court · 1984
  2. Carborundum Co. v. CommissionerUnited States Tax Court · 1978
  3. Carborundum Co. v. CommissionerUnited States Tax Court · 1980
  4. Ideal Basic Industries, Inc. v. CommissionerUnited States Tax Court · 1984

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