Estate of De Bie v. Commissioner
United States Tax Court
During the taxable years 1960, 1961, and 1962 petitioner's leased mining property had reached the development stage. Held, that all expenditures reasonably connected with preparing the two commercially marketable ore deposits in the mine for extraction, including expenditures to further delineate the location and extent of such ore deposits, constitute deductible development expenditures within the meaning of sec. 616 of the Internal Revenue Code of 1954. Held, further, the…
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During the taxable years 1960, 1961, and 1962 petitioner's leased mining property had reached the development stage. Held, that all expenditures reasonably connected with preparing the two commercially marketable ore deposits in the mine for extraction, including expenditures to further delineate the location and extent of such ore deposits, constitute deductible development expenditures within the meaning of sec. 616 of the Internal Revenue Code of 1954. Held, further, the value of certain tangible personal property donated by petitioner to a charitable organization during 1961 and 1962…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax against tbe petitioner as follows:
Tear Deficiency
1960 _$25, 345.83
1961_ 68,137.73
1962 _ 73, 729.91
Total _167,213.47
Certain issues having been conceded, tbe only issues remaining for determination are (1) whether certain amounts spent by tbe petitioner in connection with a mine constitute deductible development expenses as claimed by petitioner or nondeductible exploration expenses as determined by the respondent, and (2) tbe value of certain tangible personal property donated by tbe petitioner in 1961 and 1962 to a charitable…
2Cases cited7 opinions
- Remmer v. United StatesSupreme Court of the United States · 1954
- McGuire v. CommissionerUnited States Tax Court · 1965
- Estate of Harrison P. Shedd, Deceased First National Bank of Arizona, Phoenix v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
- Shedd v. CommissionerUnited States Tax Court · 1954
- Estate of Stoll v. CommissionerUnited States Tax Court · 1962
2 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Parker v. CommissionerUnited States Tax Court · 1986
- Skripak v. CommissionerUnited States Tax Court · 1985
- Palmer v. CommissionerUnited States Tax Court · 1974
- Guest v. CommissionerUnited States Tax Court · 1981
31 more not listed; retrieve them via the Exa API.