Legal Opinion

Washburn v. Commissioner

United States Tax Court

Decided May 27, 1965No. Docket Nos. 92521, 1198-62, 1299-62Published

Held, petitioner husband, a contract miner of uranium ore under specific written contracts, had no economic interest in the ore in place and therefore was not entitled to a deduction for percentage depletion against the income received under the mining contracts. Parsons v. Smith, 359 U.S. 215 (1959), and Paragon Coal Co. v. Commissioner, 380 U.S. 624 (1965), followed. Additions to tax for negligence sustained.

1Opinion of the Court

Lark L. Washburn and Arlea W. Washburn, Petitioners, v. Commissioner of Internal Revenue, Respondent

Washburn v. Commissioner

Docket Nos. 92521, 1198-62, 1299-62

United States Tax Court

44 T.C. 217; 1965 U.S. Tax Ct. LEXIS 84;

May 27, 1965, Filed

Decisions will be entered under Rule 50.

Held, petitioner husband, a contract miner of uranium ore under specific written contracts, had no economic interest in the ore in place and therefore was not entitled to a deduction for percentage depletion against the income received under the mining contracts. Parsons v. Smith, 359 U.S. 215 (1959), and Paragon…

2Cases cited20 opinions

  1. Courtney v. CommissionerUnited States Tax Court · 1957
  2. Parsons v. SmithSupreme Court of the United States · 1959
  3. Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
  4. Hurley v. CommissionerUnited States Tax Court · 1954
  5. Estate of Albert D. Phillips, Deceased, Viola T. Chartrand, Formerly Viola T. Phillips, Administratrix v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957

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