Tennessee Consol. Coal Co. v. Commissioner
United States Tax Court
1. The petitioner corporation during the taxable years owned in fee certain coal lands, a part of which it operated. Though consisting of 3 tracts, the land was almost entirely in 1 body. Certain "fringe" areas of the land, at a distance, were leased to other operators on a royalty basis.
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1. The petitioner corporation during the taxable years owned in fee certain coal lands, a part of which it operated. Though consisting of 3 tracts, the land was almost entirely in 1 body. Certain "fringe" areas of the land, at a distance, were leased to other operators on a royalty basis. Held that within section 114 (b) (4), Internal Revenue Code, the land was one "property." 2. Petitioner, on the accrual basis, accrued and deducted, monthly deductions for vacation payments to miners. Held that though the labor turnover was small, accrual was not proper, because the amount of vacation pay…
1Opinion of the Court
OPINION.
Disney, Judge:(1) The first question for our consideration is-whether the petitioner is entitled to accrue month by month its deductions for vacation payments due June 1 of the following year in accordance with the existing contracts between it and the United Mine Workers of America. Respondent contends that petitioner is entitled to-deduct, each year, only the amount actually paid.
The petitioner’s position is that it basically had an obligation to-make vacation payments to its miners and in accordance with the then existing contract it accrued a specific proportion each month in…
2Cases cited10 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- Aluminum Castings Co. v. RoutzahnSupreme Court of the United States · 1930
5 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Union Pacific Railroad v. United StatesUnited States Court of Claims · 1975
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1962
- Brown Paper Mill Co. v. CommissionerUnited States Tax Court · 1954
- Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1952
24 more not listed; retrieve them via the Exa API.