Bentex Oil Corp. v. Commissioner
United States Tax Court
Held, the organization, of which petitioner was a member, was a joint venture or partnership engaged in an oil drilling operation, which joint venture was entitled to an election either to deduct as necessary expenses or to capitalize intangible drilling costs.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The ultimate question for decision is whether the petitioner, in computing its excess profits credit for the years 1944 and 1945, was entitled to capitalize its proportionate share, one-fourth, of the intangible drilling and development costs of the Puig Lease Operations for the years 1938 and 1939. The petitioner elected to capitalize intangible drilling and development expenses on its 1936 income tax return pursuant to the option granted in Regulations 94, article 23 (m}-lG.1 In 1938 and 1939, however, the petitioner in conjunction with other coowners of the Puig…
2Cases cited2 opinions
- Wegener v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Scherf v. CommissionerUnited States Tax Court · 1953
3Cited by19 opinions
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- Cokes v. CommissionerUnited States Tax Court · 1988
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