Warren v. Commissioner
United States Tax Court
Petitioner, who is engaged in producing sod, sought to justify his deductions for cost of soil by claiming allowances for cost depletion on his mineral lands and percentage depletion on land containing peat soil. Without deciding whether a sod producer is entitled to any allowance for depletion, it is held petitioner failed to present sufficient evidence from which any amount of cost or percentage depletion could be computed under the statutes and applicable regulations.
1Opinion of the Court
Benedict O. Warren, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent
Warren v. Commissioner
Docket No. 91421
United States Tax Court
40 T.C. 991; 1963 U.S. Tax Ct. LEXIS 50;
September 20, 1963, Filed
Decision will be entered for the respondent.
Petitioner, who is engaged in producing sod, sought to justify his deductions for cost of soil by claiming allowances for cost depletion on his mineral lands and percentage depletion on land containing peat soil. Without deciding whether a sod producer is entitled to any allowance for depletion, it is held petitioner failed to present…
2Cases cited2 opinions
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Warren v. CommissionerUnited States Tax Court · 1963