Big Lake Oil Co. v. Commissioner
United States Board of Tax Appeals
A block of stock which was to be divided among a group of oil producers, based proportionately upon their deliveries during a period ending December 1, 1926, in fulfilling a certain contract, was not income received until they filed their agreement of division in 1927.
1Opinion of the Court
opinion.
Muedock:
The Commissioner determined a deficiency of $97,-009.85 in the petitioner’s income tax for the calendar year 1927. He also determined a deficiency for 1926, but the issue relating to that year has been waived. The only issue is whether the petitioner is taxable in 1927 with $598,571.01, representing the agreed fair market value in January 1927 of 2,450 shares of stock.of the Reagan County Purchasing Co., which the Commissioner determined were received by the petitioner in January 1927. Most of the facts in the record *1004have been stipulated. The stipulated facts will not be set…
2Cases cited1 opinion
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
3Cited by3 opinions
- Bonham v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
- Big Lake Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1936
- Marts, Inc. v. CommissionerUnited States Tax Court · 1960