Coyle v. Commissioner
United States Board of Tax Appeals
Where A sold to B all the oil produced from his interest in an oil lease during the period December 2, 1921, to October 2, 1922, for the sum of $625,000, of which the amount of $225,000 was payable at all events and the remainder was limited to an amount equal to the sale price of one-half the oil produced from such interest during said period, with an option in B to purchase said interest in the lease for the sum of $25,000, plus an amount equal to the difference between…
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Where A sold to B all the oil produced from his interest in an oil lease during the period December 2, 1921, to October 2, 1922, for the sum of $625,000, of which the amount of $225,000 was payable at all events and the remainder was limited to an amount equal to the sale price of one-half the oil produced from such interest during said period, with an option in B to purchase said interest in the lease for the sum of $25,000, plus an amount equal to the difference between the sum of $625,000 and what had been paid for oil, said latter amount to be paid out of oil, and where it was uncertain,…
1Opinion of the Court
*373OPINION.
Milliken :
The contract between petitioners and the Wichita Petroleum Co. was construed in Wichita Petroleum Co. v. Winant, 295 Fed. 67, and it was there held that the only period of time referred to in the contract was the period “commencing at midnight December 1-2, 1921, and ending at midnight October 1-2, 1922,” with the result that petitioners were entitled to be paid, in addition to the total cash payments aggregating $225,000, an amount equal to one-half of the proceeds of all oil produced from the three-fourths interest in the lease, that being petitioners’ interest which was…
2Cases cited16 opinions
- United States v. IshamSupreme Court of the United States · 1873
- Bullen v. WisconsinSupreme Court of the United States · 1916
- Edwards v. SlocumSupreme Court of the United States · 1924
- Heryford v. DavisSupreme Court of the United States · 1880
- Richardson v. HardwickSupreme Court of the United States · 1882
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3Cited by1 opinion
- Coyle v. CommissionerUnited States Board of Tax Appeals · 1929