Legal Opinion

Jahn v. Commissioner

United States Tax Court

Decided June 12, 1972No. Docket No. 5276-69Published

Petitioners owned a farm in Michigan, and on January 2, 1964, entered into an "agreement" with two individuals, Neyer and Andres, with respect to such property whereby the latter agreed to drill oil and gas wells thereon at their sole risk and expense and to market the production therefrom. Petitioners retained the rights to five-eighths of all production to be realized from the property and Neyer and Andres were to receive three-eighths of the proceeds.

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Petitioners owned a farm in Michigan, and on January 2, 1964, entered into an "agreement" with two individuals, Neyer and Andres, with respect to such property whereby the latter agreed to drill oil and gas wells thereon at their sole risk and expense and to market the production therefrom. Petitioners retained the rights to five-eighths of all production to be realized from the property and Neyer and Andres were to receive three-eighths of the proceeds. On the same day that petitioners signed the "agreement" and in conjunction therewith, petitioners received $ 50,000 from Andres. Petitioners…

1Opinion of the Court

Harold E. Jahn and Mary Jahn, Petitioners v. Commissioner of Internal Revenue, Respondent

Jahn v. Commissioner

Docket No. 5276-69

United States Tax Court

58 T.C. 452; 1972 U.S. Tax Ct. LEXIS 108; 42 Oil & Gas Rep. 502;

June 12, 1972, Filed

Decision will be entered for the respondent.

Petitioners owned a farm in Michigan, and on January 2, 1964, entered into an "agreement" with two individuals, Neyer and Andres, with respect to such property whereby the latter agreed to drill oil and gas wells thereon at their sole risk and expense and to market the production therefrom. Petitioners retained the…

2Cases cited14 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Palmer v. BenderSupreme Court of the United States · 1932
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. Anderson v. HelveringSupreme Court of the United States · 1940
  5. Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956

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