Legal Opinion

Rocky Mountain Dev. Co. v. Commissioner

United States Board of Tax Appeals

Decided December 6, 1938No. Docket No. 83849Published

1. Where petitioner, in exchange for oil well equipment, acquired certain oil payment contracts for stipulated amounts to be paid out of the proceeds from oil if, as, and when produced from the properties upon which the exchanged equipment was installed, and the petitioner's right to receive such future payments and thus recoup its cost and realize taxable profits, if any, was wholly contingent upon the indeterminable happening of future events, held, that petitioner is…

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1. Where petitioner, in exchange for oil well equipment, acquired certain oil payment contracts for stipulated amounts to be paid out of the proceeds from oil if, as, and when produced from the properties upon which the exchanged equipment was installed, and the petitioner's right to receive such future payments and thus recoup its cost and realize taxable profits, if any, was wholly contingent upon the indeterminable happening of future events, held, that petitioner is entitled to apply the payments actually received during the taxable year on each contract, respectively, in recoupment of…

1Opinion of the Court

ROCKY MOUNTAIN DEVELOPMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Rocky Mountain Dev. Co. v. Commissioner

Docket No. 83849.

United States Board of Tax Appeals

38 B.T.A. 1303; 1938 BTA LEXIS 760;

December 6, 1938, Promulgated

1. Where petitioner, in exchange for oil well equipment, acquired certain oil payment contracts for stipulated amounts to be paid out of the proceeds from oil if, as, and when produced from the properties upon which the exchanged equipment was installed, and the petitioner's right to receive such future payments and thus recoup its cost and…

2Cases cited3 opinions

  1. Burnet v. LoganSupreme Court of the United States · 1931
  2. Rocky Mountain Dev. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
  3. Cook Drilling Co. v. CommissionerUnited States Board of Tax Appeals · 1938

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