Fink v. Commissioner
United States Tax Court
1. Contracts, terminable at will, for strip mining coal, whereby a partnership, strip miner, agreed to deliver all coal mined to the lessor, owner, and receive a specified price per ton of coal delivered, held, did not give the partnership an economic interest in the coal in place so as to entitle the partnership to a depletion deduction under sections 23 (m) and 114 (b) (4), I. R. C. 1939. 2. The cancellation of a debt in return for the assignment of a claim which was in…
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1. Contracts, terminable at will, for strip mining coal, whereby a partnership, strip miner, agreed to deliver all coal mined to the lessor, owner, and receive a specified price per ton of coal delivered, held, did not give the partnership an economic interest in the coal in place so as to entitle the partnership to a depletion deduction under sections 23 (m) and 114 (b) (4), I. R. C. 1939. 2. The cancellation of a debt in return for the assignment of a claim which was in fact worthless at the time of the assignment, held, did not give rise to a bad debt loss under section 23 (k), I. R. C.…
1Opinion of the Court
Nathan Fink and Gertrude Fink, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Fink v. Commissioner
Docket Nos. 57387, 57388, 57389, 57390
United States Tax Court
29 T.C. 1119; 1958 U.S. Tax Ct. LEXIS 233;
March 20, 1958, Filed
Decisions will be entered under Rule 50.
1. Contracts, terminable at will, for strip mining coal, whereby a partnership, strip miner, agreed to deliver all coal mined to the lessor, owner, and receive a specified price per ton of coal delivered, held, did not give the partnership an economic interest in the coal in place so as to entitle the partnership…
2Cases cited15 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- United States v. LudeySupreme Court of the United States · 1927
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
10 more not listed; retrieve them via the Exa API.