Legal Opinion

Coyle v. Commissioner

United States Board of Tax Appeals

Decided September 20, 1929No. Docket Nos. 24513, 28293-28295Published

Where A sold to B all the oil produced from his interest in an oil lease during the period December 2, 1921, to October 2, 1922, for the sum of $625,000, of which the amount of $225,000 was payable at all events and the remainder was limited to an amount equal to the sale price of one-half the oil produced from such interest during said period, with an option in B to purchase said interest in the lease for the sum of $25,000, plus an amount equal to the difference between…

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Where A sold to B all the oil produced from his interest in an oil lease during the period December 2, 1921, to October 2, 1922, for the sum of $625,000, of which the amount of $225,000 was payable at all events and the remainder was limited to an amount equal to the sale price of one-half the oil produced from such interest during said period, with an option in B to purchase said interest in the lease for the sum of $25,000, plus an amount equal to the difference between the sum of $625,000 and what had been paid for oil, said latter amount to be paid out of oil, and where it was uncertain,…

1Opinion of the Court

ARTHUR J. COYLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

THOMAS W. CRAGG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

BENJAMIN H. ORR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

JOHN G. WINANT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Coyle v. Commissioner

Docket Nos. 24513, 28293-28295.

United States Board of Tax Appeals

17 B.T.A. 368; 1929 BTA LEXIS 2307;

September 20, 1929, Promulgated

Where A sold to B all the oil produced from his interest in an oil lease during the period December 2, 1921, to October 2, 1922, for the sum…

2Cases cited18 opinions

  1. United States v. IshamSupreme Court of the United States · 1873
  2. Bullen v. WisconsinSupreme Court of the United States · 1916
  3. Edwards v. SlocumSupreme Court of the United States · 1924
  4. Heryford v. DavisSupreme Court of the United States · 1880
  5. Richardson v. HardwickSupreme Court of the United States · 1882

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