Legal Opinion

Beach Petroleum Corp. v. Commissioner

United States Tax Court

Decided July 26, 1946No. Docket Nos. 3273, 1236, 1229, 1231, 1232 and 1252UnpublishedCited by 1 opinion

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

  1. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  2. Anderson v. HelveringSupreme Court of the United States · 1940
  3. General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
  4. Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938
  5. Helvering v. O'DONNELLSupreme Court of the United States · 1938

7 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Commissioner of Internal Revenue v. Hirshon TrustCourt of Appeals for the Second Circuit · 1954

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