Ledanois Land & Stone Co. v. Commissioner
United States Tax Court
The petitioner, since its incorporation in 1907, has attempted to lease its land for mineral extraction. In 1917 it leased its property for oil development; in 1925 it tried to interest persons in developing its salt deposits; in 1932 it leased part of its property for limestone extraction; in 1937 it leased for oil development; and in 1941 it again leased for oil development.
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The petitioner, since its incorporation in 1907, has attempted to lease its land for mineral extraction. In 1917 it leased its property for oil development; in 1925 it tried to interest persons in developing its salt deposits; in 1932 it leased part of its property for limestone extraction; in 1937 it leased for oil development; and in 1941 it again leased for oil development. Held, petitioner did not change the character of its business during or immediately prior to the base period nor was it committed to a course of action consummated subsequent thereto which resulted in any change in its…
1Opinion of the Court
OPINION.
Bruce, Judge:
Petitioner bases its claims for relief primarily under section 722 (b) (4), its contention being that during the base period it changed the character of its business in that it was no longer leasing its property for production of limestone but had leased it for the production of oil and gas and that this constituted a change in its capacity for production and operation of the business. It further contends that prior to January 1, 1940, it had committed itself to a course of action, consummated subsequent thereto, which resulted in a change in the capacity for production…
2Cases cited10 opinions
- Avey Drilling Machine Co. v. CommissionerUnited States Tax Court · 1951
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- National Grinding Wheel Co. v. CommissionerUnited States Tax Court · 1947
- Farmers Creamery Co. v. CommissionerUnited States Tax Court · 1952
- Clermont Groves, Inc. v. CommissionerUnited States Tax Court · 1952
5 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Ledanois Land & Stone Co. v. CommissionerUnited States Tax Court · 1957