Manahan Oil Co. v. Commissioner
United States Tax Court
1. Deductions from Income -- Intangible Drilling and Development Costs. -- Petitioner acquired an interest in leases by drilling and developing and was not entitled to deduct those costs as expenses. F. H. E. Oil Co., 3 T. C. 13; affd., 147 Fed.
Read the full summary
1. Deductions from Income -- Intangible Drilling and Development Costs. -- Petitioner acquired an interest in leases by drilling and developing and was not entitled to deduct those costs as expenses. F. H. E. Oil Co., 3 T. C. 13; affd., 147 Fed. (2d) 1002, followed. 2. Income. -- Amounts received from production from fractional interests in leases temporarily assigned to the petitioner until from those interests and others the petitioner received the equivalent of the development costs, were income to the petitioner.
1Opinion of the Court
OPINION.
Murdock, Judge'.
The Commissioner determined deficiencies of $6,316.80 and $1,459.21 in the income tax of the Manahan Oil Co. for the fiscal years ended June 30, 1940 and 1941. He also determined liabilities against the other three petitioners as transferees. The three individual petitioners concede that they are liable as transferees for any amounts due from the corporation. The latter will be referred to hereinafter as the petitioner.
The issues for decision are whether the Commissioner erred, first, in disallowing deductions taken by the petitioner for intangible drilling and…
2Cases cited2 opinions
- F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
- Horton v. CommissionerUnited States Tax Court · 1946
3Cited by17 opinions
- Estate of H. H. Weinert, Deceased, Jane W. Blumberg, and Hilda B. Weinert v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- United States v. W. H. CockeCourt of Appeals for the Fifth Circuit · 1968
- Berkshire Oil Co. v. CommissionerUnited States Tax Court · 1947
- Weinert v. CommissionerUnited States Tax Court · 1959
- Hedges v. CommissionerUnited States Tax Court · 1964
12 more not listed; retrieve them via the Exa API.