Legal Opinion

Producers Chemical Co. v. Commissioner

United States Tax Court

Decided September 26, 1968No. Docket Nos. 175-66, 1873-67Published

Petitioner purchased interests in oil leases for a consideration of a cash payment with the sellers retaining production payments payable from 85 percent as to all but one lease and 95 percent as to that lease of the production of the interest sold.

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Petitioner purchased interests in oil leases for a consideration of a cash payment with the sellers retaining production payments payable from 85 percent as to all but one lease and 95 percent as to that lease of the production of the interest sold. Held: (1) A part of petitioner's operating costs to produce oil and gas from the leases represents costs of acquiring the leases; (2) allocated overhead expenses and depreciation are part of operating costs to produce the oil and gas from the leases; and (3) under the facts of this case fracturing costs are development expenses and deductible as…

1Opinion of the Court

Producers Chemical Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Producers Chemical Co. v. Commissioner

Docket Nos. 175-66, 1873-67

United States Tax Court

50 T.C. 940; 1968 U.S. Tax Ct. LEXIS 59; 30 Oil & Gas Rep. 275;

September 26, 1968, Filed

Decisions will be entered under Rule 50.

Petitioner purchased interests in oil leases for a consideration of a cash payment with the sellers retaining production payments payable from 85 percent as to all but one lease and 95 percent as to that lease of the production of the interest sold. Held: (1) A part of petitioner's operating…

Also in this document: Concurrence; Dissent.

2Cases cited24 opinions

  1. Thomas v. PerkinsSupreme Court of the United States · 1937
  2. Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
  3. Perlmutter v. CommissionerUnited States Tax Court · 1965
  4. Shainberg v. CommissionerUnited States Tax Court · 1959
  5. Great Northern Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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