Legal Opinion

Brountas v. Commissioner

United States Tax Court

Decided December 26, 1979No. Docket Nos. 8231-76, 8497-76, 8698-77, 6255-78PublishedCited by 86 opinions

Petitioner Brountas was a limited partner in an oil and gas drilling partnership, Coral I, while petitioner CRC was a general partner in Coral I, Coral II (another similar venture), and a direct investor in other drilling ventures. Each of these ventures used the following basic format, with variations. An exploratory drilling prospect would be presented to CRC by an operator.

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Petitioner Brountas was a limited partner in an oil and gas drilling partnership, Coral I, while petitioner CRC was a general partner in Coral I, Coral II (another similar venture), and a direct investor in other drilling ventures. Each of these ventures used the following basic format, with variations. An exploratory drilling prospect would be presented to CRC by an operator. If the geology appeared favorable, CRC would purchase for itself, or cause a limited partnership such as Coral I or Coral II to purchase, the operator's leasehold interest and the operator's promise to drill to the…

1Opinion of the Court

Hall, Judge:

Respondent determined deficiencies, plus additions to the tax for fraud under section 6653(b)2 and accumulated earnings tax under section 531, as follows:

Petitioner Year Docket No. Deficiency Sec. 5S1 Sec. 6653(b)

Paul and Lynn Brountas 1972 8231-76 $6,283.35 none none

Paul and Lynn Brountas 1973 6255-78 19,006.43 none none

CRC Corp. 1972 8497-76 238,826.00 $152,485 $195,656

CRC Corp. 1973 8698-77 272,821.00 none 136,411

Petitioner Paul Brountas was a limited partner in a “leveraged” oil and gas drilling venture (Coral I), and petitioner CRC Corp. (CRC) was both the general partner and…

2Cases cited51 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Gregory v. HelveringSupreme Court of the United States · 1935
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Higgins v. SmithSupreme Court of the United States · 1940
  5. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978

46 more not listed; retrieve them via the Exa API.

3Cited by86 opinions

  1. Brannen v. CommissionerUnited States Tax Court · 1982
  2. Siegel v. CommissionerUnited States Tax Court · 1982
  3. Surloff v. CommissionerUnited States Tax Court · 1983
  4. Fox v. CommissionerUnited States Tax Court · 1983
  5. Estate of Baron v. CommissionerUnited States Tax Court · 1984

81 more not listed; retrieve them via the Exa API.

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