Stantex Petroleum Co. v. Commissioner
United States Board of Tax Appeals
The Stantex Petroleum Co., lessee of an oil and gas lease, sold undivided interests therein accompanied by an agreement to drill a well on the leased property at its own expense.
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The Stantex Petroleum Co., lessee of an oil and gas lease, sold undivided interests therein accompanied by an agreement to drill a well on the leased property at its own expense. Oil and gas were discovered in paying quantities, and during the taxable periods, the assignor, in accordance with provisions of the assignments, operated the lease and, as agent for the holders of undivided interests, sold the output of the wells and distributed the proceeds, less costs of operation, to the leaseholders. Held, that the petitioners are not associations taxable as corporations.
1Opinion of the Court
OPINION.
Disney:
These proceedings were consolidated for hearing and report and involve redetermination of the following deficiencies:
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The question presented for decision is whether the petitioners are associations taxable as corporations. The facts are embodied in stipulations of fact which are adopted by reference as our findings of fact.
Immediately after its organization in 1931 under the laws of Oklahoma the Stantex Petroleum Co. acquired by assignment;, in exchange for 130 shares of its capital stock, an oil and gas lease covering a tract of land in Texas. Thereafter in 1931…
2Cases cited4 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Helvering v. Coleman-Gilbert AssociatesSupreme Court of the United States · 1935
- Swanson v. CommissionerSupreme Court of the United States · 1935
- Helvering v. CombsSupreme Court of the United States · 1935
3Cited by6 opinions
- John Province 1 Well v. CommissionerUnited States Tax Court · 1961
- Lease v. CommissionerUnited States Tax Court · 1944
- Cord v. CommissionerUnited States Board of Tax Appeals · 1938
- John Province 1 Well v. CommissionerUnited States Tax Court · 1961
- Stantex Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1938
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