Legal Opinion

Ideal Basic Industries, Inc. v. Commissioner

United States Tax Court

Decided February 29, 1984No. Docket No. 11847-78Published

Potash Corp. of America (PCA), a division of petitioner, mines and concentrates sylvinite ore, producing five grades of potassium chloride, or muriate of potash, which it sells primarily for use as an agricultural fertilizer.

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Potash Corp. of America (PCA), a division of petitioner, mines and concentrates sylvinite ore, producing five grades of potassium chloride, or muriate of potash, which it sells primarily for use as an agricultural fertilizer. The Commissioner agrees that the muriate produced by flotation constitutes mining for the purpose of computing petitioner's allowance for percentage depletion but determined that PCA's treatment processes, involving the leaching and crystallization of muriate "fines" and dust in order to produce its soluble and chemical grade muriate, are refining or manufacturing…

1Opinion of the Court

Ideal Basic Industries, Inc., and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Ideal Basic Industries, Inc. v. Commissioner

Docket No. 11847-78

United States Tax Court

82 T.C. 352; 1984 U.S. Tax Ct. LEXIS 101; 82 T.C. No. 28;

February 29, 1984, Filed

Decision will be entered under Rule 155.

Potash Corp. of America (PCA), a division of petitioner, mines and concentrates sylvinite ore, producing five grades of potassium chloride, or muriate of potash, which it sells primarily for use as an agricultural fertilizer. The Commissioner agrees that the muriate produced by…

2Cases cited25 opinions

  1. United States v. Cannelton Sewer Pipe Co.Supreme Court of the United States · 1960
  2. Alabama By-Products Corporation v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
  3. Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
  4. Stemkowski v. CommissionerUnited States Tax Court · 1981
  5. North Carolina Granite Corp. v. CommissionerUnited States Tax Court · 1964

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