Legal Opinion
Wendland v. Commissioner
Court of Appeals for the Eleventh Circuit
Decided August 21, 1984No. 83-5443PublishedCited by 16 opinions
1Per curiam
Appellants are limited partners in Tennessee Coal Resources, Ltd. (TCR), a partnership formed on December 30, 1976. On December 31, 1976, TCR acquired a coal mining lease. Characterizing the entire cost of acquisition as an advanced royalty, TCR claimed a deduction of $3,000,000 on its 1976 return, part of which was passed through to appellants. Because no coal was mined in 1976, the Commissioner disallowed the deduction. The Commissioner based its decision on a 1977 amendment to Treas.Reg. § 1.612-3(b)(3) which provided, as here relevant, that advanced royalties are deducted from gross…
2Cases cited7 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- United States v. SullivanSupreme Court of the United States · 1927
- Russell Redhouse, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Wendland v. CommissionerUnited States Tax Court · 1982
- Elkins v. CommissionerUnited States Tax Court · 1983
2 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Willard K. Baker and Irene L. Baker v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Butka v. CommissionerUnited States Tax Court · 1988
- Conoco, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Long v. United StatesUnited States Court of Claims · 1986
11 more not listed; retrieve them via the Exa API.