Legal Opinion

Roberts v. Commissioner

United States Tax Court

Decided July 30, 1948No. Docket Nos. 9763, 9764Unpublished

Petitioners acquired a one-half interest in an oil lease in return for their agreement to pay one-half of the intangible drilling costs incident to the sinking of a well. Held, that this expenditure by petitioners was to them a cost of the property acquired and not subject to deduction as an expense under section 23 (m) of the Internal Revenue Code.

1Opinion of the Court

J. I. Roberts v. Commissioner. Helen M. Roberts v. Commissioner.

Roberts v. Commissioner

Docket Nos. 9763, 9764.

United States Tax Court

1948 Tax Ct. Memo LEXIS 125; 7 T.C.M. (CCH) 536; T.C.M. (RIA) 48139;

July 30, 1948

Petitioners acquired a one-half interest in an oil lease in return for their agreement to pay one-half of the intangible drilling costs incident to the sinking of a well. Held, that this expenditure by petitioners was to them a cost of the property acquired and not subject to deduction as an expense under section 23 (m) of the Internal Revenue Code.

C. Ellis Henican, Esq., for the…

2Cases cited3 opinions

  1. F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
  2. Manahan Oil Co. v. CommissionerUnited States Tax Court · 1947
  3. Hardesty v. CommissionerUnited States Board of Tax Appeals · 1941

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