Johnson Inv. & Rental Co. v. Commissioner
United States Tax Court
P "leased" certain property to X, which operated a quarry thereon and paid P 5 cents for each ton of rock sold by it from stone quarried on the premises. Held, the payments by X were mineral royalties within the meaning of sec. 543, I.R.C. 1954, and as a result, P was a personal holding company subject to tax under sec. 541, I.R.C. 1954. Held, further, the amount of P's deduction for qualified indebtedness determined.
1Opinion of the Court
Johnson Investment & Rental Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Johnson Inv. & Rental Co. v. Commissioner
Docket No. 834-76
United States Tax Court
70 T.C. 895; 1978 U.S. Tax Ct. LEXIS 62;
September 11, 1978, Filed
Decision will be entered under Rule 155.
P "leased" certain property to X, which operated a quarry thereon and paid P 5 cents for each ton of rock sold by it from stone quarried on the premises. Held, the payments by X were mineral royalties within the meaning of sec. 543, I.R.C. 1954, and as a result, P was a personal holding company subject to tax under…
2Cases cited16 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Burnet v. HarmelSupreme Court of the United States · 1932
- Aquilino v. United StatesSupreme Court of the United States · 1960
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Palmer v. BenderSupreme Court of the United States · 1932
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