United States v. Hill
Supreme Court of the United States
1Opinion of the CourtJustice Souter
Under §§56 and 57(a)(8) of the Internal Revenue Code of 1954, 26 U. S. C. §§56, 57(a)(8) (1976 ed.), a taxpayer must pay a “minimum tax” on the excess of the allowable depletion deduction for an interest in a mineral deposit over the taxpayer’s adjusted basis for that interest. The question presented here is whether the term “adjusted basis,” as used in § 57(a)(8), includes certain depreciable drilling and development costs identified in § 1.612-4(c)(l) of the Treasury Department regulations. We hold that the term does not cover such costs.
I
In 1981 and 1982, respondents William F. and Lola E.…
2Cases cited6 opinions
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
- Choate v. CommissionerSupreme Court of the United States · 1945
- William F. Hill and Lola E. Hill v. The United StatesCourt of Appeals for the Federal Circuit · 1991
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- E.I. Du Pont de Nemours & Co. v. CommissionerUnited States Tax Court · 1994
- Legal Environmental Assistance Foundation, Inc. v. United States Environmental Protection AgencyCourt of Appeals for the Eleventh Circuit · 1997
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