Kewanee Oil Co. v. Commissioner
United States Tax Court
In 1965 T Corp., a domestic corporation engaged exclusively in the production of oil and gas in Canada, sold in a single transaction substantially all of its oil- and gas-producing property, all of its associated production equipment, and 70 percent of the net undeveloped acreage it then held. Its only gross income during the 3-year period immediately preceding the close of its taxable year in 1965 consisted of the gain realized by reason of that sale.
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In 1965 T Corp., a domestic corporation engaged exclusively in the production of oil and gas in Canada, sold in a single transaction substantially all of its oil- and gas-producing property, all of its associated production equipment, and 70 percent of the net undeveloped acreage it then held. Its only gross income during the 3-year period immediately preceding the close of its taxable year in 1965 consisted of the gain realized by reason of that sale. Held: T failed to qualify as a "Western Hemisphere trade corporation" in 1965 under sec. 921(2) which required that 90 percent or more of its…
1Opinion of the Court
Kewanee Oil Company and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent
Kewanee Oil Co. v. Commissioner
Docket No. 5965-72
United States Tax Court
62 T.C. 728; 1974 U.S. Tax Ct. LEXIS 53; 62 T.C. No. 79;
August 29, 1974, Filed
Decision will be entered under Rule 155.
In 1965 T Corp., a domestic corporation engaged exclusively in the production of oil and gas in Canada, sold in a single transaction substantially all of its oil- and gas-producing property, all of its associated production equipment, and 70 percent of the net undeveloped acreage it then held. Its only gross…
2Cases cited4 opinions
- Commissioner v. LesterSupreme Court of the United States · 1961
- United States v. Boston Buick Co.Supreme Court of the United States · 1931
- Babson Bros. Export Co. v. CommissionerUnited States Tax Court · 1963
- Kewanee Oil Co. v. CommissionerUnited States Tax Court · 1974