Ray v. Commissioner
United States Tax Court
Petitioner, owner of certain timberlands, entered into a contract with the Mengel Company in the taxable year 1952, which provided, inter alia, that he was to produce 40,000 cords of pulpwood from his tracts of land over an 8-year period. Petitioner was to cut the timber involved or have it cut. Only in the event of his default in cutting, removing, and shipping the pulpwood was Mengel to have the right to enter petitioner's land and perform the cutting operations.
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Petitioner, owner of certain timberlands, entered into a contract with the Mengel Company in the taxable year 1952, which provided, inter alia, that he was to produce 40,000 cords of pulpwood from his tracts of land over an 8-year period. Petitioner was to cut the timber involved or have it cut. Only in the event of his default in cutting, removing, and shipping the pulpwood was Mengel to have the right to enter petitioner's land and perform the cutting operations. Petitioner arranged for his two sons, who were partners doing business under the name of Ray Naval Stores, to cut the trees…
1Opinion of the Court
Joe S. Ray, Petitioner, v. Commissioner of Internal Revenue, Respondent
Ray v. Commissioner
Docket No. 69322
United States Tax Court
32 T.C. 1244; 1959 U.S. Tax Ct. LEXIS 82;
September 23, 1959, Filed
Decision will be entered under Rule 50.
Petitioner, owner of certain timberlands, entered into a contract with the Mengel Company in the taxable year 1952, which provided, inter alia, that he was to produce 40,000 cords of pulpwood from his tracts of land over an 8-year period. Petitioner was to cut the timber involved or have it cut. Only in the event of his default in cutting, removing, and shipping…
2Cases cited15 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Renwick v. United StatesCourt of Appeals for the Seventh Circuit · 1936
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