Legal Opinion

Manahan Oil Co. v. Commissioner

United States Tax Court

Decided May 29, 1947No. Docket Nos. 9669, 9664, 9666, 9668Published

1. Deductions from Income -- Intangible Drilling and Development Costs. -- Petitioner acquired an interest in leases by drilling and developing and was not entitled to deduct those costs as expenses. F. H. E. Oil Co., 3 T. C. 13; affd., 147 Fed.

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1. Deductions from Income -- Intangible Drilling and Development Costs. -- Petitioner acquired an interest in leases by drilling and developing and was not entitled to deduct those costs as expenses. F. H. E. Oil Co., 3 T. C. 13; affd., 147 Fed. (2d) 1002, followed. 2. Income. -- Amounts received from production from fractional interests in leases temporarily assigned to the petitioner until from those interests and others the petitioner received the equivalent of the development costs, were income to the petitioner.

1Opinion of the Court

Manahan Oil Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. G. A. Manahan, Petitioner, v. Commissioner of Internal Revenue, Respondent. R. D. Creighton, Petitioner, v. Commissioner of Internal Revenue, Respondent. Pearl V. Manahan, Petitioner, v. Commissioner of Internal Revenue, Respondent

Manahan Oil Co. v. Commissioner

Docket Nos. 9669, 9664, 9666, 9668

United States Tax Court

8 T.C. 1159; 1947 U.S. Tax Ct. LEXIS 191;

May 29, 1947, Promulgated

Decisions will be entered for the respondent.

1. Deductions from Income -- Intangible Drilling and Development Costs. -- Petitioner…

2Cases cited3 opinions

  1. F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
  2. Manahan Oil Co. v. CommissionerUnited States Tax Court · 1947
  3. Horton v. CommissionerUnited States Tax Court · 1946

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