Crooks v. Commissioner
United States Tax Court
Petitioners owned a farm under which oil was discovered in 1981. In 1982, petitioners conveyed all of their interest in the minerals underlying the farm to Henry Energy Corp. in consideration for four other farms, new farm equipment, and a one-fourth royalty interest in all oil and gas produced from the conveyed mineral interest.
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Petitioners owned a farm under which oil was discovered in 1981. In 1982, petitioners conveyed all of their interest in the minerals underlying the farm to Henry Energy Corp. in consideration for four other farms, new farm equipment, and a one-fourth royalty interest in all oil and gas produced from the conveyed mineral interest. Held: Petitioners retained an economic interest in the minerals underlying the farm by retaining a right to receive a specified percentage of all the oil and gas produced. Petitioners looked solely to the extraction of the minerals underlying the farm for a return of…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income taxes for the following taxable years:
Taxable year Deficiency
1982. $733,357.81
1983. 3,128.85
Petitioners have conceded the Commissioner’s adjustments in disallowing, in 1983, utility expenses in the amount of $1,515.60, gasoline expenses in the amount of $520, and depreciation expense in the amount of $3,222, and have conceded an increase in the investment tax credit for 1983 in the amount of $500.30. There are no issues remaining for our decision for the taxable year 1983. After concessions, the issues…
2Cases cited24 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Anderson v. HelveringSupreme Court of the United States · 1940
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
19 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Sprint Corp. v. CommissionerUnited States Tax Court · 1997
- Crooks v. CommissionerUnited States Tax Court · 1989
- Muldavin v. CommissionerUnited States Tax Court · 1991
- Sprint Corp. v. CommissionerUnited States Tax Court · 1997
- Sprint Corporation and Subsidiaries, f.k.a. United Telecommunications, Inc. v. CommissionerUnited States Tax Court · 1997