Legal Opinion

Stradlings Bldg. Materials, Inc. v. Commissioner

United States Tax Court

Decided January 14, 1981No. Docket No. 11468-78Published

Held, on the facts, prepaid intangible drilling expenses pursuant to a binding contract allowed despite failure of contractor to perform services in subsequent tax year.

1Opinion of the Court

Stradlings Building Materials, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Stradlings Bldg. Materials, Inc. v. Commissioner

Docket No. 11468-78

United States Tax Court

76 T.C. 84; 1981 U.S. Tax Ct. LEXIS 191; 68 Oil & Gas Rep. 563;

January 14, 1981, Filed

Decision will be entered for the petitioner.

Held, on the facts, prepaid intangible drilling expenses pursuant to a binding contract allowed despite failure of contractor to perform services in subsequent tax year.

Dale E. Andersen, for the petitioner.

Dennis C. DeBerry, for the respondent.

Hall, Judge.

HALL

OPINION

Respondent…

2Cases cited17 opinions

  1. Remmer v. United StatesSupreme Court of the United States · 1954
  2. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  3. United States v. FlannerySupreme Court of the United States · 1925
  4. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  5. Riss v. CommissionerUnited States Tax Court · 1971

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