Lee v. Commissioner
United States Board of Tax Appeals
Petitioners are the owners of ten oil payment contracts which entitle them to specified amounts payable out of oil if, as, and when produced.
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Petitioners are the owners of ten oil payment contracts which entitle them to specified amounts payable out of oil if, as, and when produced. Some of the contracts were acquired by cash purchases and some as payment for drilling and equipping oil wells, and others involve situations where the petitioners had been the owners of the oil and gas leases and had sold such interests to others for stipulated considerations and in addition had retained the right to receive other specified amounts from a fractional part of the oil, if, as, and when produced. Applying the reasoning of the Supreme Court…
1Opinion of the Court
*1222OPINION.
TtteneR:
In his determination of the deficiencies the respondent included in gross income the full amount of collections under the ten oil payment contracts and allowed deductions for depletion with respect to each as shown in our findings of fact. The petitioners have alleged that the respondent erred in his inclusion in gross income of the full amounts collected, claiming that they are entitled to recoup the costs of their oil payment contracts before the amounts received are to be included in gross income. The respondent denies that he erred as petitioners allege, and further, by…
2Cases cited7 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Anderson v. HelveringSupreme Court of the United States · 1940
- Thomas v. PerkinsSupreme Court of the United States · 1937
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
2 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- United States v. Raymond H. Witte and Lillian B. WitteCourt of Appeals for the Fifth Circuit · 1962
- Lee v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
- Eastern Coal Corporation v. YokeDistrict Court, N.D. West Virginia · 1946
- Watnick v. CommissionerUnited States Tax Court · 1988
- Osceola Heard Davenport v. CommissionerUnited States Tax Court · 1953
8 more not listed; retrieve them via the Exa API.