Legal Opinion

Freeman v. Commissioner

United States Tax Court

Decided April 28, 1967No. Docket Nos. 2416-65, 2417-65, 2418-65, 1362-66PublishedCited by 1 opinion

A partnership composed of petitioners made an agreement with Shell Oil Co. to grant to it certain oil, gas, and sulphur interests by five separate conveyances, two of which were to cover several tracts and the other three to cover one tract each, for which a bonus was to be paid.

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A partnership composed of petitioners made an agreement with Shell Oil Co. to grant to it certain oil, gas, and sulphur interests by five separate conveyances, two of which were to cover several tracts and the other three to cover one tract each, for which a bonus was to be paid. The leases were executed, the bonus paid, and depletion deductions of 27 1/2 percent of the bonus claimed and allowed to the partnership in its computation of its distributable income in years prior to 1962. In 1962 the leases expired as to certain of the tracts without production having been obtained on those…

1Opinion of the Court

OPINION

Scott, Judge:

Respondent determined deficiencies in the income tax of petitioners for the taxable year ended December 31, 1962, in the following amounts:

Docket No. Petitioners Deficiency

2416-65 Norman and Ernestine H. Freeman_$8, 772.28

2417-65 Albert H. and Lee Benson Halff_ 8,410. 30

2418-65 Mayer H. and Maureene Halff_ 24, 090. 93

1362-66 George W. and Betty Halff Llewellyn_ 22, 330. 86

In their respective petitions, petitioners Norman and Ernestine EL Freeman and petitioners Albert H. and Lee Benson Halff claim over-payments in their 'income tax for the calendar year 1962.

The issue for…

2Cases cited18 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Herring v. CommissionerSupreme Court of the United States · 1934
  3. Douglas v. CommissionerSupreme Court of the United States · 1944
  4. Berkshire Oil Co. v. CommissionerUnited States Tax Court · 1947
  5. Sneed v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941

13 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Freeman v. CommissionerUnited States Tax Court · 1967

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