Ohio River Collieries Co. v. Commissioner
United States Tax Court
Petitioner, a taxpayer using the accrual method of accounting, is engaged in strip-mining coal in Ohio. Under the law of that State, strip miners are required, inter alia, to file a reclamation plan accompanied by a surety bond equal to the total estimated reclamation cost.
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Petitioner, a taxpayer using the accrual method of accounting, is engaged in strip-mining coal in Ohio. Under the law of that State, strip miners are required, inter alia, to file a reclamation plan accompanied by a surety bond equal to the total estimated reclamation cost. The parties agree that petitioner's estimate of the cost of reclamation work required by the reclamation law, but not accomplished as of the close of the taxable year in question, was computed with reasonable accuracy. Held: Petitioner may deduct its accrued reclamation costs for the taxable year in question since as of…
1Opinion of the Court
OPINION
Nims, Judge:
Respondent determined deficiencies in petitioner’s income tax for the tax year ending June 30, 1975, in the amount of $112,515.67. Petitioner claims an overpayment of income tax in the amount of $85,166.80 for such year.
Due to concessions by the petitioner, the only issue remaining for decision is whether petitioner, an accrual basis taxpayer, may deduct the reasonably estimated expenses necessary to satisfy its obligation under Ohio law to reclaim strip-mined land in the year it incurred the obligation.
The facts of this case are fully stipulated. The stipulation and its…
2Cases cited21 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Brown v. HelveringSupreme Court of the United States · 1934
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Harrold v. Commissioner of Internal Revenue. Cromling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1951
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
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3Cited by21 opinions
- Illinois Power Co. v. CommissionerUnited States Tax Court · 1986
- Burlington N. R. Co. v. CommissionerUnited States Tax Court · 1984
- Kaiser Steel Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1983
- Exxon Mobil Corp. v. CommissionerUnited States Tax Court · 2000
- Long v. United StatesUnited States Court of Claims · 1986
16 more not listed; retrieve them via the Exa API.