Legal Opinion

Burns v. Commissioner

United States Tax Court

Decided February 8, 1982No. Docket Nos. 7139-79, 9564-79, 9914-79, 9915-79, 9916-79, 9917-79Published

Petitioners purchased working interests in oil and gas leases and entered into turnkey drilling and completion contracts and other agreements with the sellers-promoters. Petitioners paid in cash the full amounts of "intangible drilling and development costs" allowable in sec. 1.612-4, Income Tax Regs.

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Petitioners purchased working interests in oil and gas leases and entered into turnkey drilling and completion contracts and other agreements with the sellers-promoters. Petitioners paid in cash the full amounts of "intangible drilling and development costs" allowable in sec. 1.612-4, Income Tax Regs. However, 50 percent of such costs were simultaneously returned to petitioners by use of bank loans made to them equal to 50 percent of the costs, fully collateralized by certificates of deposit pledged by the promoters. Repayments of the loans were from 50 percent of the net profits from…

1Opinion of the Court

Richard L. Burns and Joyce C. Burns, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Burns v. Commissioner

Docket Nos. 7139-79, 9564-79, 9914-79, 9915-79, 9916-79, 9917-79

United States Tax Court

78 T.C. 185; 1982 U.S. Tax Ct. LEXIS 138; 78 T.C. No. 14; 73 Oil & Gas Rep. 195;

February 8, 1982, Filed

Decisions will be entered under Rule 155.

Petitioners purchased working interests in oil and gas leases and entered into turnkey drilling and completion contracts and other agreements with the sellers-promoters. Petitioners paid in cash the full amounts of "intangible drilling and…

2Cases cited20 opinions

  1. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  2. United States v. PhellisSupreme Court of the United States · 1921
  3. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  4. Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
  5. Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938

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