Legal Opinion

Chaparral Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided January 30, 1941No. Docket No. 97552Published

LOSS DEDUCTION - OIL AND GAS ROYALTY - RETENTION OF TITLE AND SUBSEQUENT RECOUPMENT. - In 1932 petitioner purchased an oil and gas royalty interest in certain land situated in Kansas. In 1935 new developments established that the land was structurally below the water line of the adjacent field, and thus excluded from commercial production.

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LOSS DEDUCTION - OIL AND GAS ROYALTY - RETENTION OF TITLE AND SUBSEQUENT RECOUPMENT. - In 1932 petitioner purchased an oil and gas royalty interest in certain land situated in Kansas. In 1935 new developments established that the land was structurally below the water line of the adjacent field, and thus excluded from commercial production. On advice of its consulting geologist, petitioner charged off its investment during the taxable year 1935, and claimed the amount as a deduction from gross income, although it retained title to its royalty interest. In 1936 petitioner received $600 rental…

1Opinion of the Court

CHAPARRAL OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Chaparral Oil Co. v. Commissioner

Docket No. 97552.

United States Board of Tax Appeals

43 B.T.A. 457; 1941 BTA LEXIS 1502;

January 30, 1941, Promulgated

LOSS DEDUCTION - OIL AND GAS ROYALTY - RETENTION OF TITLE AND SUBSEQUENT RECOUPMENT. - In 1932 petitioner purchased an oil and gas royalty interest in certain land situated in Kansas. In 1935 new developments established that the land was structurally below the water line of the adjacent field, and thus excluded from commercial production. On advice of its…

2Cases cited4 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  3. Chaparral Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Fell v. CommissionerUnited States Board of Tax Appeals · 1927

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