Legal Opinion

Bear Canon Coal Co. v. Commissioner

United States Board of Tax Appeals

Decided January 14, 1929No. Docket No. 9502PublishedCited by 1 opinion

INCOME - EXEMPTION. - Petitioner's income derived from the sale of coal mined by it from school lands owned by the State of Colorado and leased by petitioner for coal-mining purposes, held, not exempt from Federal income and profits taxes, under authority of Coronado Oil & Gas Co.,14 B.T.A. 1214.

1Opinion of the Court

*1246OPINION.

Trttssell:

No issue has been raised as to the correctness of the respondent’s computation of petitioner’s net income and the taxes thereon for the years in question. The only issue is whether petitioner is exempt from Federal income and profits taxes, and if it is not exempt, then the deficiencies are in the amounts as determined by respondent.

Petitioner contends that in holding, using, and disposing of school lands and the proceeds and increments thereof, the State of Colorado exercises its governmental powers and functions; that in the exercise of such powers the State of Colorado…

2Cited by1 opinion

  1. Bear Canon Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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