Davis v. Commissioner
United States Tax Court
1. P and others were partners in PS, a coal mining joint venture. PS acquired by lease the rights to mine coal from the properties of various landowner-lessors. PS then subleased these rights to a corporation, WC, which carried out the actual mining and paid royalties to PS. PS paid yearly advanced minimum royalties to the landowners before coal was mined and earned royalties per ton as coal was mined.
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1. P and others were partners in PS, a coal mining joint venture. PS acquired by lease the rights to mine coal from the properties of various landowner-lessors. PS then subleased these rights to a corporation, WC, which carried out the actual mining and paid royalties to PS. PS paid yearly advanced minimum royalties to the landowners before coal was mined and earned royalties per ton as coal was mined. Earned royalties due the landowners were reduced by credits for earlier unearned advanced royalties paid. PS and each of its partners reported all royalties received from WC, the mining…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Petitioner(s) Docket No. Year Deficiency
Joe C. Davis 6540-77 1967 $2,562.55
1968 39,926.07
1969 43,827,58
1970 28,660.40
1971 33,501.26
Joe C. Davis 6319-78 1972 398,422.68
1973 63,673.85
1974 65,240.58
1975 59,781.49
Estate of Rascoe B. Davis, deceased, Third National Bank, executor, and Delta C. Davis
6540-77
1967 114.18
1968 1,172.93
1969 1,521.49
1970 1,791.68
1971 2,027.86
These cases have been consolidated for purposes of trial, briefing, and opinion.
Because of concessions, the remaining issues…
2Cases cited60 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Burnet v. HarmelSupreme Court of the United States · 1932
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Palmer v. BenderSupreme Court of the United States · 1932
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3Cited by30 opinions
- Brannen v. CommissionerUnited States Tax Court · 1982
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- Goodwin v. CommissionerUnited States Tax Court · 1980
- Tobler v. DerwinskiUnited States Court of Appeals for Veterans Claims · 1991
- Clyde Brown, Jr. v. United StatesCourt of Appeals for the Sixth Circuit · 1986
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