Legal Opinion

Big Four Oil & Gas Co. v. Commissioner

United States Tax Court

Decided October 14, 1957No. Docket Nos. 57107, 57108Published

Excess Profits Tax -- Net Abnormal Income Attributable to Prior Years -- Sec. 456 (a) (2) (B). -- A producing "discovery" oil well or wells having been completed in an oil pool covered by petitioners' leases less than a year after the beginning of "exploration, discovery, or prospecting" by petitioners relating to the area covered by such leases, petitioners have failed to show that the income from such pool claimed to be abnormal resulted from "exploration, discovery, or…

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Excess Profits Tax -- Net Abnormal Income Attributable to Prior Years -- Sec. 456 (a) (2) (B). -- A producing "discovery" oil well or wells having been completed in an oil pool covered by petitioners' leases less than a year after the beginning of "exploration, discovery, or prospecting" by petitioners relating to the area covered by such leases, petitioners have failed to show that the income from such pool claimed to be abnormal resulted from "exploration, discovery, or prospecting" extending over a period of more than 12 months as required by the provisions of section 456 (a) (2) (B), I.…

1Opinion of the Court

The Big Four Oil & Gas Company, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent. Southwestern Oil and Gas Company, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Big Four Oil & Gas Co. v. Commissioner

Docket Nos. 57107, 57108

United States Tax Court

29 T.C. 31; 1957 U.S. Tax Ct. LEXIS 66; 8 Oil & Gas Rep. 119;

October 14, 1957, Filed

Decisions will be entered for respondent.

Excess Profits Tax -- Net Abnormal Income Attributable to Prior Years -- Sec. 456 (a) (2) (B). -- A producing "discovery" oil well or wells having been completed in an oil…

2Cases cited5 opinions

  1. Halle v. CommissionerUnited States Tax Court · 1946
  2. M. C. Parrish & Co. v. CommissionerUnited States Tax Court · 1944
  3. M. C. Parrish & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
  4. Rissman v. CommissionerUnited States Tax Court · 1946
  5. Big Four Oil & Gas Co. v. CommissionerUnited States Tax Court · 1957

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