Wood v. Commissioner
United States Tax Court
1. A community fee interest in oil- and gas-producing properties is taxable on the income from that fee interest where the entire interest in the properties is burdened with the repayment of advances made on behalf of that interest. Anderson v. Helvering, 310 U.S. 404 (1940). One-half of the community fee interest was received in a divorce and property settlement.
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1. A community fee interest in oil- and gas-producing properties is taxable on the income from that fee interest where the entire interest in the properties is burdened with the repayment of advances made on behalf of that interest. Anderson v. Helvering, 310 U.S. 404 (1940). One-half of the community fee interest was received in a divorce and property settlement. Held, the one-half interest was a present interest in the properties and the income from that one-half interest, which was applied to the prior community indebtedness on the properties, is taxable to the holder of that interest. 2.…
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in petitioner’s income taxes and additions to the tax for the years 1951 and 1952 as follows:
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The issues are (1) whether petitioner is taxable on one-half of the income from a 45 per cent interest in a joint oil venture during the years in question; (2) whether the amount of income allocable to one-third of the one-half interest, which petitioner assigned to Sam I. Pittman, is taxable to her; and (3) whether respondent computed the allowance for depletion on gross income as required by sections 23 (m) and 114 (b) (3) of the Internal…
2Cases cited9 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Helvering v. TaylorSupreme Court of the United States · 1935
- Freuler v. HelveringSupreme Court of the United States · 1934
- Anderson v. HelveringSupreme Court of the United States · 1940
- Thomas v. PerkinsSupreme Court of the United States · 1937
4 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Estate of H. H. Weinert, Deceased, Jane W. Blumberg, and Hilda B. Weinert v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- Indiana Broadcasting Corp. v. CommissionerUnited States Tax Court · 1964
- Weinert v. CommissionerUnited States Tax Court · 1959
- Carl A. Prater and Della Jane C. Prater, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Myrtle J. Wood v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
6 more not listed; retrieve them via the Exa API.