Beach Petroleum Corp. v. Commissioner
United States Tax Court
A corporation distributed to its stockholders in 1940 participating oil royalty interests in wells it operated under lease. These interests had a cost basis of zero to the corporation and a fair market value of $68,000 when distributed. The stock of the corporation had a cost basis of zero to the stockholders and was held by them over 24 months.
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A corporation distributed to its stockholders in 1940 participating oil royalty interests in wells it operated under lease. These interests had a cost basis of zero to the corporation and a fair market value of $68,000 when distributed. The stock of the corporation had a cost basis of zero to the stockholders and was held by them over 24 months. Held, (1) following General Utilities & Operating Co. v. Helvering, 296 U.S. 200, the corporation did not realize upon such distribution taxable income from the appreciation in value of such interests while held by it; (2) the appreciation in value of…
1Opinion of the Court
Beach Petroleum Corporation, Ltd., et al. 1 v. Commissioner.
Beach Petroleum Corp. v. Commissioner
Docket Nos. 3273, 1236, 1229, 1231, 1232 and 1252.
United States Tax Court
1946 Tax Ct. Memo LEXIS 126; 5 T.C.M. (CCH) 638; T.C.M. (RIA) 46192;
July 26, 1946
A corporation distributed to its stockholders in 1940 participating oil royalty interests in wells it operated under lease. These interests had a cost basis of zero to the corporation and a fair market value of $68,000 when distributed. The stock of the corporation had a cost basis of zero to the stockholders and was held by them over 24 months.…
2Cases cited12 opinions
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Anderson v. HelveringSupreme Court of the United States · 1940
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938
- Helvering v. O'DONNELLSupreme Court of the United States · 1938
7 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Commissioner of Internal Revenue v. Hirshon TrustCourt of Appeals for the Second Circuit · 1954