Texas Pipeline Co. v. Commissioner
United States Board of Tax Appeals
1. A taxpayer is not entitled, under section 204(c)(1) of the Revenue Act of 1926, to compute depletion of a sulphur mine on the basis of the discovery value to its predecessor in title. 2. The evidence does not sustain respondent's affirmative claim for the disallowance of a deduction of the cost to petitioner of maintaining a "stock investment or profit-sharing plan" by which part of petitioner's employees were permitted, through a trustee, to purchase certain stock at…
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1. A taxpayer is not entitled, under section 204(c)(1) of the Revenue Act of 1926, to compute depletion of a sulphur mine on the basis of the discovery value to its predecessor in title. 2. The evidence does not sustain respondent's affirmative claim for the disallowance of a deduction of the cost to petitioner of maintaining a "stock investment or profit-sharing plan" by which part of petitioner's employees were permitted, through a trustee, to purchase certain stock at less than its fair market value, said deduction having been previously allowed by the Commissioner.
1Opinion of the Court
THE TEXAS PIPE LINE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Texas Pipeline Co. v. Commissioner
Docket No. 59457.
United States Board of Tax Appeals
32 B.T.A. 125; 1935 BTA LEXIS 996;
February 20, 1935, Promulgated
1. A taxpayer is not entitled, under section 204(c)(1) of the Revenue Act of 1926, to compute depletion of a sulphur mine on the basis of the discovery value to its predecessor in title.
2. The evidence does not sustain respondent's affirmative claim for the disallowance of a deduction of the cost to petitioner of maintaining a "stock investment or…
2Cases cited1 opinion
- Texas Pipeline Co. v. CommissionerUnited States Board of Tax Appeals · 1935