Thomas v. Commissioner (A)
United States Tax Court
Petitioner, who had knowledge of and experience in prospecting phosphate-bearing land and who at the time was conducting such prospecting for landowners, and one Holland, who owned a parcel of such land, planned and entered upon a venture of assembling phosphate acreage of such size, location, and phosphate content as to be of interest to a phosphate-mining company.
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Petitioner, who had knowledge of and experience in prospecting phosphate-bearing land and who at the time was conducting such prospecting for landowners, and one Holland, who owned a parcel of such land, planned and entered upon a venture of assembling phosphate acreage of such size, location, and phosphate content as to be of interest to a phosphate-mining company. They at all times intended to sell the assembled acreage and at no time intended to mine phosphate or have it mined on a royalty basis. Over a period of more than 2 years, they prospected lands for phosphate, arranged for…
1Opinion of the Court
Robert Thomas and Susan B. Thomas, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Thomas v. Commissioner (A)
Docket No. 52435
United States Tax Court
28 T.C. 1; 1957 U.S. Tax Ct. LEXIS 228;
April 4, 1957, Filed
Decision will be entered under Rule 50.
Petitioner, who had knowledge of and experience in prospecting phosphate-bearing land and who at the time was conducting such prospecting for landowners, and one Holland, who owned a parcel of such land, planned and entered upon a venture of assembling phosphate acreage of such size, location, and phosphate content as to…
2Cases cited3 opinions
- Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- Warner Mountains Lumber Co. v. CommissionerUnited States Tax Court · 1947
- Thomas v. Commissioner (A)United States Tax Court · 1957