Allen v. Commissioner
United States Tax Court
1. The petitioner was married and owned an oil and gas business on July 26, 1945, the effective date of the Oklahoma community property law. In 1946, a net loss was sustained.
Read the full summary
1. The petitioner was married and owned an oil and gas business on July 26, 1945, the effective date of the Oklahoma community property law. In 1946, a net loss was sustained. Held, for carry-back purposes the portion of the loss resulting from the cancellation of leases, which were property acquired by petitioner prior to July 26, 1945, was his loss, and the remainder, in the absence of any evidence tracing all or some portion of it to property acquired by him prior to that date, was a community loss as determined by the respondent. 2. The net loss sustained from the operation of the…
1Opinion of the Court
W. O. Allen, Petitioner, v. Commissioner of Internal Revenue, Respondent
Allen v. Commissioner
Docket No. 31798
United States Tax Court
22 T.C. 70; 1954 U.S. Tax Ct. LEXIS 239; 3 Oil & Gas Rep. 689;
April 20, 1954, Filed April 20, 1954, Filed
Decision will be entered under Rule 50.
1. The petitioner was married and owned an oil and gas business on July 26, 1945, the effective date of the Oklahoma community property law. In 1946, a net loss was sustained. Held, for carry-back purposes the portion of the loss resulting from the cancellation of leases, which were property acquired by petitioner prior…
2Cases cited13 opinions
- Commissioner v. HarmonSupreme Court of the United States · 1944
- Sanders v. CommissionerUnited States Tax Court · 1954
- Hammonds v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1939
- Trapp v. United StatesCourt of Appeals for the Tenth Circuit · 1949
- Johnson v. CommissionerUnited States Tax Court · 1943
8 more not listed; retrieve them via the Exa API.