Bayou Verret Land Co. v. Commissioner
United States Tax Court
In each of the years 1959 through 1963, petitioner received bonuses upon the execution of oil and gas leases, and claimed percentage depletion thereon. In each of the succeeding years, 1960 through 1964, respectively, the lease of the immediately preceding year was terminated without production, and, pursuant to sec. 1.612-3(a)(2), Income Tax Regs., petitioner returned as income a sum equal to the depletion deduction claimed for the immediately preceding year.
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In each of the years 1959 through 1963, petitioner received bonuses upon the execution of oil and gas leases, and claimed percentage depletion thereon. In each of the succeeding years, 1960 through 1964, respectively, the lease of the immediately preceding year was terminated without production, and, pursuant to sec. 1.612-3(a)(2), Income Tax Regs., petitioner returned as income a sum equal to the depletion deduction claimed for the immediately preceding year. Respondent determined that petitioner was subject to the personal holding company tax for 1959, 1960, 1961, 1963, and 1964. Held, the…
1Opinion of the Court
OPINION
A. Personal holdmg company issues. — The years here in controversy, 1959 through 1964, span significant changes in the personal holding company tax provisions. Amendments, enacted by the Beve-nne Act of 1964, Pub. L. 88-272, 78 Stat. 19, apply to taxable years beginning after December 81, 1963. The issue is whether, under the applicable statute, petitioner is subject to the personal holding company tax for each of the years before the Court.
1. Pre-1961 years. — Petitioner’s income for 1959 through 1968 consisted only of (1) bonuses received on the execution of oil and gas leases4 and…
2Cases cited36 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Anderson v. HelveringSupreme Court of the United States · 1940
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
31 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Burck v. CommissionerUnited States Tax Court · 1975
- Prabel v. CommissionerUnited States Tax Court · 1988
- Bayou Verret Land Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1971
- Opine Timber Co. v. CommissionerUnited States Tax Court · 1975
- Estate of Ratliff v. CommissionerUnited States Tax Court · 1993
25 more not listed; retrieve them via the Exa API.