Legal Opinion

Heberer v. Commissioner

United States Tax Court

Decided May 30, 1974No. Docket No. 8997-72UnpublishedCited by 3 opinions

Petitioner, Donald Heberer, entered into an oil and gas drilling program under which he agreed to pay $13,500 to Drilling Co. for drilling a well on a location assigned to him under a lease held by Transmission Co., an affiliate of the drilling company.

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Petitioner, Donald Heberer, entered into an oil and gas drilling program under which he agreed to pay $13,500 to Drilling Co. for drilling a well on a location assigned to him under a lease held by Transmission Co., an affiliate of the drilling company. Petitioner paid $2,700 in cash in 1969 and purportedly borrowed $10,800 from Leasing Co., parent of Transmission Co., to pay to Drilling Co. Payments on the note were to begin in January of 1970 and were to be paid from amounts Transmission agreed to pay petitioner for oil recovered from his well, whether Transmission actually took the oil or…

1Opinion of the Court

DONALD L. HEBERER AND NORMA A. HEBERER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Heberer v. Commissioner

Docket No. 8997-72.

United States Tax Court

T.C. Memo 1974-139; 1974 Tax Ct. Memo LEXIS 180; 33 T.C.M. (CCH) 626; T.C.M. (RIA) 74139; 48 Oil & Gas Rep. 403;

May 30, 1974, Filed.

Petitioner, Donald Heberer, entered into an oil and gas drilling program under which he agreed to pay $13,500 to Drilling Co. for drilling a well on a location assigned to him under a lease held by Transmission Co., an affiliate of the drilling company. Petitioner paid $2,700 in cash in 1969 and…

2Cases cited2 opinions

  1. Haass v. CommissionerUnited States Tax Court · 1970
  2. Commissioner v. Estate of DonnellCourt of Appeals for the Fifth Circuit · 1969

3Cited by3 opinions

  1. Stradlings Bldg. Materials, Inc. v. CommissionerUnited States Tax Court · 1981
  2. Sanderson v. CommissionerUnited States Tax Court · 1977
  3. Stradlings Bldg. Materials, Inc. v. CommissionerUnited States Tax Court · 1981

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