Legal Opinion

Jefferson Lake Sulphur Co. v. United States

District Court, E.D. Louisiana

Decided May 25, 1962No. Civ. A. No. 6879PublishedCited by 2 opinions

1Opinion of the Court

AINSWORTH, District Judge.

The taxpayer, Jefferson Lake Sulphur Company, sues for refund of income taxes. The Commissioner of Internal Revenue determined that for purposes of computing its depletion deduction Jefferson Lake should exclude from its gross income the royalty paid by Jefferson Lake to others on sulphur it mined for Texas Gulf Sulphur Company pursuant to a written contract between the two companies. We disagree, and hold that refund should be granted.

On October 25, 1943, Jefferson Lake entered into a mineral agreement with Texas Gulf, subsequently amended May 15, 1950. Production…

2Cases cited4 opinions

  1. Palmer v. BenderSupreme Court of the United States · 1932
  2. Anderson v. HelveringSupreme Court of the United States · 1940
  3. Mrs. Harold S. Willingham Nee Francis S. McCall v. Life & Casualty Insurance Company of TennesseeCourt of Appeals for the Fifth Circuit · 1954
  4. Midland Valley R. v. Railway Express Agency, Inc.Court of Appeals for the Tenth Circuit · 1939

3Cited by2 opinions

  1. Shuford Development Company v. Chrysler CorporationCourt of Appeals for the Fifth Circuit · 1971
  2. Shuford Development Company v. Chrysler CorporationCourt of Appeals for the Fifth Circuit · 1971

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