Morrisdale Coal Mining Co. v. Commissioner
United States Tax Court
1. Taxpayer, an operator of coal mines for many years, in June 1940 leased certain property for the purpose of developing a coal mine thereon. In March 1942 it leased additional contiguous property containing the same coal seam for the same purpose.
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1. Taxpayer, an operator of coal mines for many years, in June 1940 leased certain property for the purpose of developing a coal mine thereon. In March 1942 it leased additional contiguous property containing the same coal seam for the same purpose. About May 1940 it commenced development on the first property, which was extended by the end of the development period, September 30, 1942, over a substantial area in the coal seam of the second property, all the coal therefrom being removed through the slope outlet in the first property. Held, that the property under the two leases constituted a…
1Opinion of the Court
OPINION.
Van Foss an, Judge:
The petitioner contends that its income for 1943 from the Maxton Slope Mine was income of a separate class within the purview of section 721 (a) (2) (C) of the Internal Revenue Code;1 that such income was abnormal to the extent of $150,855.90, the amount by which petitioner’s 1943 gross income exceeded 125 per cent of its gross income from this class during the four preceding years; and that its net abnormal income, as defined in section 721 (a) (3),2 of $92,594.02 is attributable to the prior years 1940, 1941, and 1942.
The respondent contends that the income…
2Cases cited4 opinions
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Black Mountain Corp. v. CommissionerUnited States Tax Court · 1945
- Gifford-Hill & Co. v. CommissionerUnited States Tax Court · 1948
3Cited by22 opinions
- Switzer v. CommissionerUnited States Tax Court · 1953
- Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1952
- Graves Bros. Co. v. CommissionerUnited States Tax Court · 1952
- Powell-Hackney Grocery Co. v. CommissionerUnited States Tax Court · 1952
- Ohio Machine Tool Co. v. CommissionerUnited States Tax Court · 1952
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