Hardesty v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
1Opinion of the Court
McCORD, Circuit Judge.
The Board of Tax Appeals sustained a determination by the Commissioner that certain intangible drilling and development costs were not deductible from taxpayers’ gross income as ordinary and necessary business expenses under Article 23(m)-16 of Treasury Regulations 94, Section 23(a) Revenue Act of 1936, 26 U.S.C.A. Int.Rev. Acts, page 827. The findings and well-reasoned opinion of the Board are reported in full, Hardesty v. Commissioner, 43 B.T.A. 245, and for this reason it is not necessary to give a detailed review of the facts and history of the case.
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2Cases cited5 opinions
- Commissioner of Internal Revenue v. AmbroseCourt of Appeals for the Fifth Circuit · 1942
- State Consol. Oil Co. v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1933
- United States v. Sentinel Oil Co.Court of Appeals for the Ninth Circuit · 1940
- Hardesty v. CommissionerUnited States Board of Tax Appeals · 1941
- State Consolidated Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1930
3Cited by16 opinions
- F. H. E. Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Commissioner of Int. Rev. v. Rowan Drilling Co.Court of Appeals for the Fifth Circuit · 1942
- FHE Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Southwest Exploration Co. v. CommissionerUnited States Tax Court · 1952
- Hunt v. CommissionerCourt of Appeals for the Fifth Circuit · 1943
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