Walker v. Commissioner
United States Board of Tax Appeals
1. The petitioners reported in their returns for the years 1921, 1922, 1923, and 1924, upon the installment basis, the amounts of cash actually received by them in those years from their interests in an oil and gas lease. Held, upon the facts that the petitioners are taxable in the years 1923 and 1924 upon the amounts of cash actually received by them and reported in their returns for those years. 2. Deductions for depletion allowances on the lease denied.
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1. The petitioners reported in their returns for the years 1921, 1922, 1923, and 1924, upon the installment basis, the amounts of cash actually received by them in those years from their interests in an oil and gas lease. Held, upon the facts that the petitioners are taxable in the years 1923 and 1924 upon the amounts of cash actually received by them and reported in their returns for those years. 2. Deductions for depletion allowances on the lease denied. H. C. Walker, Jr., et al.,6 B.T.A. 1142.
1Opinion of the Court
*3OPINION.
Smith:
The petitioners make the contention that the income in dispute was taxable to them in 1921 and 1922 when under the terms of the agreement of June 23, 1920, the oil produced from their royalty interest was sold and the proceeds from such sales were deposited in the City Savings Bank & Trust Company to their credit. The respondent contends that there was a completed sale by the petitioners of their royalty interest in the lease at the time of the execution of the agreement and that since the petitioners elected to report their income from the sale on the installment basis, that…
2Cases cited2 opinions
- Houston Belt & Terminal Ry. Co. v. United StatesCourt of Appeals for the Fifth Circuit · 1918
- Blalock v. Georgia Ry. & Electric Co.Court of Appeals for the Fifth Circuit · 1917
3Cited by2 opinions
- Murray v. CommissionerUnited States Board of Tax Appeals · 1933
- Walker v. CommissionerUnited States Board of Tax Appeals · 1931