Donnell v. Commissioner
United States Tax Court
Held: 1. Petitioners are entitled to deduct as intangible drilling and development expenses certain amounts paid in 1959 and 1960 for drilling on four illegally deviated oil wells bottomed outside of property on which they had a working interest in a lease. 2. Petitioners are not entitled to depletion allowance deductions in 1961 and 1962 with respect to oil produced from four illegally deviated oil wells bottomed outside of property on which they had a working interest in a…
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Held: 1. Petitioners are entitled to deduct as intangible drilling and development expenses certain amounts paid in 1959 and 1960 for drilling on four illegally deviated oil wells bottomed outside of property on which they had a working interest in a lease. 2. Petitioners are not entitled to depletion allowance deductions in 1961 and 1962 with respect to oil produced from four illegally deviated oil wells bottomed outside of property on which they had a working interest in a lease because they had no "economic interest" in the oil in place. However, petitioners are entitled to depletion…
1Opinion of the Court
Estate of H. W. Donnell, Deceased, Willie Hayden Donnell, Executrix, and Mrs. Willie Hayden Donnell, Petitioners v. Commissioner of Internal Revenue, Respondent
Donnell v. Commissioner
Docket Nos. 2752-65, 2753-65, 2754-65
United States Tax Court
48 T.C. 552; 1967 U.S. Tax Ct. LEXIS 71; 26 Oil & Gas Rep. 887;
July 13, 1967, Filed
Decisions will be entered under Rule 50.
Held: 1. Petitioners are entitled to deduct as intangible drilling and development expenses certain amounts paid in 1959 and 1960 for drilling on four illegally deviated oil wells bottomed outside of property on which they had a…
2Cases cited32 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Eisner v. MacOmberSupreme Court of the United States · 1920
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
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