Legal Opinion

Island Gas, Inc. v. Commissioner

United States Tax Court

Decided June 30, 1958No. Docket No. 61047Published

Petitioner, an accrual basis taxpayer, agreed to pay Kuhn the sum of $ 175,500 advanced by him for drilling 9 gas wells on leaseholds owned three-fourths by petitioner and one-fourth by Kuhn.

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Petitioner, an accrual basis taxpayer, agreed to pay Kuhn the sum of $ 175,500 advanced by him for drilling 9 gas wells on leaseholds owned three-fourths by petitioner and one-fourth by Kuhn. Of that amount petitioner allocated $ 139,327.30 to intangible development costs and deducted it as an expense for the year 1950, under Regulations 111, section 29.23 (m)-16. Commissioner determined that only $ 6,700.53 of the total amount of intangible development costs was actually repaid to Kuhn, a cash basis taxpayer and a controlling stockholder, within 1950 and 2 1/2 months thereafter. Disallowance…

1Opinion of the Court

Island Gas, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Island Gas, Inc. v. Commissioner

Docket No. 61047

United States Tax Court

30 T.C. 787; 1958 U.S. Tax Ct. LEXIS 134; 9 Oil & Gas Rep. 848;

June 30, 1958, Filed

Decision will be entered under Rule 50.

Petitioner, an accrual basis taxpayer, agreed to pay Kuhn the sum of $ 175,500 advanced by him for drilling 9 gas wells on leaseholds owned three-fourths by petitioner and one-fourth by Kuhn. Of that amount petitioner allocated $ 139,327.30 to intangible development costs and deducted it as an expense for the year 1950, under…

2Cases cited8 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. McAdams v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
  3. Platt Trailer Co. v. CommissionerUnited States Tax Court · 1955
  4. Wisconsin Memorial Park Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
  5. Wooten v. CommissionerUnited States Tax Court · 1949

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