Davis v. Commissioner
United States Tax Court
1. P and others were partners in PS, a coal mining joint venture. PS acquired by lease the rights to mine coal from the properties of various landowner-lessors. PS then subleased these rights to a corporation, WC, which carried out the actual mining and paid royalties to PS. PS paid yearly advanced minimum royalties to the landowners before coal was mined and earned royalties per ton as coal was mined.
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1. P and others were partners in PS, a coal mining joint venture. PS acquired by lease the rights to mine coal from the properties of various landowner-lessors. PS then subleased these rights to a corporation, WC, which carried out the actual mining and paid royalties to PS. PS paid yearly advanced minimum royalties to the landowners before coal was mined and earned royalties per ton as coal was mined. Earned royalties due the landowners were reduced by credits for earlier unearned advanced royalties paid. PS and each of its partners reported all royalties received from WC, the mining…
1Opinion of the Court
Joe C. Davis, Estate of Rascoe B. Davis, Third National Bank, Executor, and Delta C. Davis, Petitioners v. Commissioner of Internal Revenue, Respondent; Joe C. Davis, Petitioner v. Commissioner of Internal Revenue, Respondent
Davis v. Commissioner
Docket Nos. 6540-77, 6319-78
United States Tax Court
74 T.C. 881; 1980 U.S. Tax Ct. LEXIS 89;
July 31, 1980, Filed
Decisions will be entered under Rule 155.
1. P and others were partners in PS, a coal mining joint venture. PS acquired by lease the rights to mine coal from the properties of various landowner-lessors. PS then subleased these rights to a…
Also in this document: Concurrence; Concurring in part, dissenting in part; Dissent · Tannenwald; Dissent · Goffe.
2Cases cited81 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Burnet v. HarmelSupreme Court of the United States · 1932
- Dobson v. CommissionerSupreme Court of the United States · 1944
- United States v. CartwrightSupreme Court of the United States · 1973
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