Mullins v. Commissioner
United States Tax Court
Held, a partnership composed of petitioners had an economic interest in coal in place under two leases which entitled it to a deduction for percentage depletion, but had no economic interest in coal in place under a third lease because the lessor reserved the right to terminate it on 60 days' notice.
1Opinion of the Court
Dawson, Judge:
In these consolidated proceedings the respondent determined the following income tax deficiencies and additions to tax against the petitioners:
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Some issues have been agreed to by the parties. The only issue for decision is whether the Mullins Coal Co., of which the petitioners were partners, had an economic interest in the coal in place under three leases so as to be entitled to a deduction for percentage depletion. The parties have agreed that our decision with respect to this issue will be determinative of the additions to tax under sections 6651 (a) and 6654.
BINDI…
2Cases cited11 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Parsons v. SmithSupreme Court of the United States · 1959
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
- United States v. James C. And Helen M. Stallard, and Dewey H. And Geneva StallardCourt of Appeals for the Fourth Circuit · 1959
- Bolling v. CommissionerUnited States Tax Court · 1962
6 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Weaver v. CommissionerUnited States Tax Court · 1979
- Kenneth Whitmer and Beatrice Whitmer v. Commissioner of Internal Revenue. William E. Heitzman and Mary Heitzman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
- Bakertown Coal Co. v. United StatesUnited States Court of Claims · 1973
- Victory Sand & Concrete, Inc. v. CommissionerUnited States Tax Court · 1974
- Holbrook v. CommissionerUnited States Tax Court · 1975
17 more not listed; retrieve them via the Exa API.