Legal Opinion

Harmel v. Commissioner

United States Board of Tax Appeals

Decided March 24, 1930No. Docket No. 38855Published

The petitioner in 1924 executed oil and gas leases covering land owned by him. The leases provided, in addition to the usual royalty, for a cash consideration which was paid to the petitioner in that year. Held that the leases were not sales of capital assets within the meaning of section 208 of the Revenue Act of 1924, and that the petitioner is not entitled to the benefits of that section.

1Opinion of the Court

HENRY HARMEL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Harmel v. Commissioner

Docket No. 38855.

United States Board of Tax Appeals

19 B.T.A. 376; 1930 BTA LEXIS 2409;

March 24, 1930, Promulgated

The petitioner in 1924 executed oil and gas leases covering land owned by him. The leases provided, in addition to the usual royalty, for a cash consideration which was paid to the petitioner in that year. Held that the leases were not sales of capital assets within the meaning of section 208 of the Revenue Act of 1924, and that the petitioner is not entitled to the benefits of that…

2Cases cited1 opinion

  1. Harmel v. CommissionerUnited States Board of Tax Appeals · 1930

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