RLC Indus. Co. v. Commissioner
United States Tax Court
P, a large timber user, combined its Oregon and California timber into a single block for purposes of computing its depletion under secs. 611 and 631, I.R.C.
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P, a large timber user, combined its Oregon and California timber into a single block for purposes of computing its depletion under secs. 611 and 631, I.R.C. R determined and contends that: (1) P's approach is not permissible under the regulations; (2) even if P's approach is permissible, it is not the method which most clearly reflects income; and (3) in any event sec. 1.611-3(d)(5), Income Tax Regs., provides R with discretional authority to change timber accounts even where they may be kept under permissible methods. P contends that: (1) Its approach is permissible under the regulations;…
1Opinion of the Court
GERBER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
TYE Deficiency
3/31/78 $2,171,826
3/31/79 972,853
3/31/80 2,006,426
3/31/82 65,254
3/31/83 3,444,367
The sole unagreed issue in this case is whether petitioner properly computed its timber depletion allowance during fiscal years ending March 31, 1980, 1982, and 1983 by combining all its merchantable1 fee timber into one composite depletion account. Respondent disallowed this combination and recomputed petitioner's depletion for these years using two depletion accounts separately reflecting petitioner's…
2Cases cited47 opinions
- Hamling v. United StatesSupreme Court of the United States · 1974
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. CaceresSupreme Court of the United States · 1979
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Batterton v. FrancisSupreme Court of the United States · 1977
42 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Ansley-Sheppard-Burgess Co. v. CommissionerUnited States Tax Court · 1995
- Bank One Corp. v. Comm'rUnited States Tax Court · 2003
- Ford Motor Co. v. CommissionerUnited States Tax Court · 1994
- Huffman v. CommissionerCourt of Appeals for the Sixth Circuit · 2008
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
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