Wilbert Mineral Corp. v. Commissioner
United States Board of Tax Appeals
Where certain mineral lands were transferred to petitioner in consideration for all of petitioner's capital stock and the transferors in the acts of transfer reserved the first $400,000 of revenues from the lands, and during the taxable years here involved the revenues did not exceed the $400,000 and were all paid over to one of the transferors on its own account and as the assignee of the other transferor, it is held that the revenues earned during the taxable years…
Read the full summary
Where certain mineral lands were transferred to petitioner in consideration for all of petitioner's capital stock and the transferors in the acts of transfer reserved the first $400,000 of revenues from the lands, and during the taxable years here involved the revenues did not exceed the $400,000 and were all paid over to one of the transferors on its own account and as the assignee of the other transferor, it is held that the revenues earned during the taxable years belonged to and were owned by the transferor to whom they were paid and that the revenues in question were not taxable to…
1Opinion of the Court
WILBERT MINERAL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Wilbert Mineral Corp. v. Commissioner
Docket No. 76529.
United States Board of Tax Appeals
38 B.T.A. 355; 1938 BTA LEXIS 874;
August 23, 1938, Promulgated
Where certain mineral lands were transferred to petitioner in consideration for all of petitioner's capital stock and the transferors in the acts of transfer reserved the first $400,000 of revenues from the lands, and during the taxable years here involved the revenues did not exceed the $400,000 and were all paid over to one of the transferors on its own…
2Cases cited12 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Palmer v. BenderSupreme Court of the United States · 1932
- Thomas v. PerkinsSupreme Court of the United States · 1937
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
- Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938
7 more not listed; retrieve them via the Exa API.