Legal Opinion

Crooks v. Commissioner

United States Tax Court

Decided April 17, 1989No. Docket No. 2055-87Published

Petitioners owned a farm under which oil was discovered in 1981. In 1982, petitioners conveyed all of their interest in the minerals underlying the farm to Henry Energy Corp. in consideration for four other farms, new farm equipment, and a one-fourth royalty interest in all oil and gas produced from the conveyed mineral interest.

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Petitioners owned a farm under which oil was discovered in 1981. In 1982, petitioners conveyed all of their interest in the minerals underlying the farm to Henry Energy Corp. in consideration for four other farms, new farm equipment, and a one-fourth royalty interest in all oil and gas produced from the conveyed mineral interest. Held: Petitioners retained an economic interest in the minerals underlying the farm by retaining a right to receive a specified percentage of all the oil and gas produced. Petitioners looked solely to the extraction of the minerals underlying the farm for a return of…

1Opinion of the Court

Richard Wayne Crooks and Maxine L. Crooks, Petitioners v. Commissioner of Internal Revenue, Respondent

Crooks v. Commissioner

Docket No. 2055-87

United States Tax Court

92 T.C. 816; 1989 U.S. Tax Ct. LEXIS 54; 92 T.C. No. 49; 104 Oil & Gas Rep. 191;

April 17, 1989. April 17, 1989, Filed

Decision will be entered under Rule 155.

Petitioners owned a farm under which oil was discovered in 1981. In 1982, petitioners conveyed all of their interest in the minerals underlying the farm to Henry Energy Corp. in consideration for four other farms, new farm equipment, and a one-fourth royalty interest in all…

2Cases cited25 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Palmer v. BenderSupreme Court of the United States · 1932
  3. Anderson v. HelveringSupreme Court of the United States · 1940
  4. Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
  5. Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932

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