Commissioner v. Engle
Supreme Court of the United States
1Opinion of the CourtJustice O’Connor
These consolidated cases present the question whether §§611-613A of the Internal Revenue Code (Code), 26 U. S. C. §§611-613A, entitle taxpayers to an allowance for percentage depletion on lease bonus or advance royalty income received from lessees of their oil and gas mineral interests.
I
A
Ever since enacting the earliest income tax laws, Congress has subsidized the development of our Nation’s natural resources. Toward this end, Congress has allowed holders of economic interests in mineral deposits, including oil and gas wells, to deduct from their taxable incomes the larger of two depletion…
Also in this document: Dissent.
2Cases cited25 opinions
- Albemarle Paper Co. v. MoodySupreme Court of the United States · 1975
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Lorillard v. PonsSupreme Court of the United States · 1978
- Southeastern Community College v. DavisSupreme Court of the United States · 1979
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
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3Cited by209 opinions
- Yuri D. Veprinsky v. Fluor Daniel, Inc.Court of Appeals for the Seventh Circuit · 1996
- Smith v. Director, Division of TaxationSupreme Court of New Jersey · 1987
- Bresgal v. BrockCourt of Appeals for the Ninth Circuit · 1987
- Goswami v. American Collections Enterprise, Inc.Court of Appeals for the Fifth Circuit · 2004
- Rafic Saadeh v. Fawaz FaroukiCourt of Appeals for the D.C. Circuit · 1997
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