Watnick v. Commissioner
United States Tax Court
In a lottery, petitioner acquired from the U.S. Department of Interior a mineral lease on 311.53 acres of land in Wyoming which was not within any known geologic structure of a producing oil or gas field.
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In a lottery, petitioner acquired from the U.S. Department of Interior a mineral lease on 311.53 acres of land in Wyoming which was not within any known geologic structure of a producing oil or gas field. He transferred a one-third interest in the lease to Melbourne and on Oct. 3, 1982, he and Melbourne assigned the lease to Exxon in consideration of a cash payment, retaining a purported production payment of $ 10,000 per acre payable out of 5 percent of any oil or gas marketed from the lease. Held, based on the record, there was no reasonable prospect or expectation that the lease would…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined deficiencies in income tax and additions to the tax as follows:
Sheldon S. Watnick and Susan Watnick
Additions to tax
Sec. 6653(a)(1), Sec. 6653(a)(2), Sec. 6661,
Year Deficiency I.R.C. 1954 I.R.C. 1954 I.R.C. 1954
1978 $345.00 0 0 0
1979 24,674.58 $1,233.73 0 0
Sheldon S. Watnick
Additions to tax
Sec. 6653(a)(1), Sec. 6653(a)(2), Sec. 6661,
Year Deficiency I.R.C. 1954 I.R.C. 1954 I.R.C. 1954
1980 $34,510.44 $1,725.52 0 0
1981 30,160.83 1,508.04 (1) 0
Sheldon S. Watnick and Elizabeth Fay Taylor-Watnick
Additions to tax
Sec. 6653(a)(1), Sec. 6653(a)(2), Sec. 6661,
Year…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Victory Carriers, Inc. v. LawSupreme Court of the United States · 1971
22 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Richard M. And Brenda R. Yates v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1991
- Yates v. CommissionerUnited States Tax Court · 1989
- Watnick v. CommissionerUnited States Tax Court · 1988
- Yates v. CommissionerUnited States Tax Court · 1989