Beck v. Commissioner
United States Tax Court
1. Fair market value of petitioner's interest in iron ore lands determined as of March 2, 1919. 2. Held, the respondent did not err in applying the "dilution theory" in section 23 (m), I. R. C., in reducing the petitioner's allowance for depletion. 3. Under the terms of a compromise agreement by which petitioner acquired iron ore lands and cash from the estate of her father, it was provided that petitioner would pay the proportionate share of Federal estate and State…
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1. Fair market value of petitioner's interest in iron ore lands determined as of March 2, 1919. 2. Held, the respondent did not err in applying the "dilution theory" in section 23 (m), I. R. C., in reducing the petitioner's allowance for depletion. 3. Under the terms of a compromise agreement by which petitioner acquired iron ore lands and cash from the estate of her father, it was provided that petitioner would pay the proportionate share of Federal estate and State inheritance taxes. It was further provided in the agreement that the trustee (under the will of petitioner's father) would…
1Opinion of the Court
Marion A. Burt Beck, Petitioner, v. Commissioner of Internal Revenue, Respondent
Beck v. Commissioner
Docket No. 20112
United States Tax Court
15 T.C. 642; 1950 U.S. Tax Ct. LEXIS 46;
November 16, 1950, Promulgated
Decision will be entered under Rule 50.
1. Fair market value of petitioner's interest in iron ore lands determined as of March 2, 1919.
2. Held, the respondent did not err in applying the "dilution theory" in section 23 (m), I. R. C., in reducing the petitioner's allowance for depletion.
3. Under the terms of a compromise agreement by which petitioner acquired iron ore lands and cash from…
2Cases cited16 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Blair v. CommissionerSupreme Court of the United States · 1937
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