Anderson v. Commissioner
United States Tax Court
Petitioners failed to establish that amounts paid and nonrecourse notes delivered to Einar C. Erickson, consulting geologist, in 1978 were paid or incurred for the development of a mine or other natural deposit. Such sums, therefore, are not deductible under sec. 616, I.R.C. 1954 as amended. Petitioners in related cases are not relieved of their stipulation to be bound by the result in these cases.
1Opinion of the Court
Cohen, Judge:
Respondent determined deficiencies as follows:
Year ended Deficiency Docket Petitioners No.
$32,598 Morris E. and Marlene H. Anderson 2761-83 OO t> 05 tH
32,226 Robert K. and Shirley S. Clawson 2763-83 OO r-05 r — 1
The primary issue for decision is whether amounts paid to Einar C. Erickson, a consulting geologist, allegedly for mining development expenses, are deductible under section 616.1 Petitioners contend that the expenses related to a joint venture among themselves, Erickson, and Erickson’s company for development of the Diamond Mine.
A secondary issue is whether petitioners in…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Estate of De Bie v. CommissionerUnited States Tax Court · 1971
- Lazisky v. CommissionerUnited States Tax Court · 1979
- Magnolia Surf, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1980
4 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Parker v. CommissionerUnited States Tax Court · 1986
- Thomas v. CommissionerUnited States Tax Court · 1985
- Adams v. CommissionerUnited States Tax Court · 1985
- Snyder v. CommissionerUnited States Tax Court · 1986
- Clawson (Robert K., Shirley S.) v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1988
13 more not listed; retrieve them via the Exa API.