Brennen v. Commissioner
United States Tax Court
1. On October 25, 1937, H. C. Frick Coke Co. conveyed to petitioner and his wife coal underlying two tracts of land covering approximately 50 acres. Thereafter, and during the taxable years, the coal was mined. Part of the coal was sold as raw coal, but the slack was processed and sold as coke.
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1. On October 25, 1937, H. C. Frick Coke Co. conveyed to petitioner and his wife coal underlying two tracts of land covering approximately 50 acres. Thereafter, and during the taxable years, the coal was mined. Part of the coal was sold as raw coal, but the slack was processed and sold as coke. The cost of mining the coal, processing the coke, and the sale of both came from a joint bank account of petitioner and his wife, and all of the proceeds from such operation were deposited in such joint account. In the respective taxable years, petitioner and his wife each claimed ownership of one-half…
1Opinion of the Court
George K. Brennen, Petitioner, v. Commissioner of Internal Revenue, Respondent
Brennen v. Commissioner
Docket Nos. 3567, 3568
United States Tax Court
4 T.C. 1260; 1945 U.S. Tax Ct. LEXIS 177;
April 30, 1945, Promulgated
Decision will be entered under Rule 50.
1. On October 25, 1937, H. C. Frick Coke Co. conveyed to petitioner and his wife coal underlying two tracts of land covering approximately 50 acres. Thereafter, and during the taxable years, the coal was mined. Part of the coal was sold as raw coal, but the slack was processed and sold as coke. The cost of mining the coal, processing the coke,…
Also in this document: Dissent.
2Cases cited23 opinions
- Madden v. Glosztonyi Savings & Trust Co.Supreme Court of Pennsylvania · 1938
- Beihl v. MartinSupreme Court of Pennsylvania · 1912
- Berhalter v. BerhalterSupreme Court of Pennsylvania · 1934
- O'Malley v. O'MalleySupreme Court of Pennsylvania · 1922
- Gasner v. PierceSupreme Court of Pennsylvania · 1926
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