Coronado Oil & Gas Co. v. Commissioner
United States Board of Tax Appeals
1. INCOME - LEASE - EXEMPTION - GOVERNMENT INSTRUMENTALITY. - Petitioner's income derived from the sale of oil and gas produced by it from school lands owned by the State of Oklahoma and leased by petitioner for oil and gas purposes, held, not exempt from Federal income and profits taxes as, under the facts proven, petitioner is not shown to be such an instrumentality of the State of Oklahoma in its performance of a governmental function, that a tax upon its income…
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1. INCOME - LEASE - EXEMPTION - GOVERNMENT INSTRUMENTALITY. - Petitioner's income derived from the sale of oil and gas produced by it from school lands owned by the State of Oklahoma and leased by petitioner for oil and gas purposes, held, not exempt from Federal income and profits taxes as, under the facts proven, petitioner is not shown to be such an instrumentality of the State of Oklahoma in its performance of a governmental function, that a tax upon its income constitutes an interference with the exercise by that State of a sovereign power. 2. INVESTED CAPITAL. - Upon the evidence, held,…
1Opinion of the Court
*1226OPINION.
Tettssell:
The taxes here involved are for the calendar years 1917, 1918, and 1919, and the deficiencies appealed from have been determined under the Revenue Acts of 1910, 1917, and 1918. By section 10 of the first mentioned Act, which is carried into the two subsequent Acts, a tax is imposed upon the net income of “ every corporation, joint stock company or association, or insurance company, organized in the United States, no matter how created or organized ”, with the exception of corporations .operated for certain *1227specified purposes, which need not be here detailed, as it is not…
2Cases cited33 opinions
- M'culloch v. State of MarylandSupreme Court of the United States · 1819
- Osborn v. Bank of United StatesSupreme Court of the United States · 1824
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Weston and Others v. the City Council of CharlestonSupreme Court of the United States · 1829
- South Carolina v. United StatesSupreme Court of the United States · 1905
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3Cited by4 opinions
- A. T. Jergins Trust v. CommissionerUnited States Board of Tax Appeals · 1931
- Bear Canon Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Coronado Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Niles v. CommissionerUnited States Board of Tax Appeals · 1930