Legal Opinion

G. B. R. Oil Corp. v. Commissioner

United States Board of Tax Appeals

Decided October 18, 1939No. Docket No. 92604PublishedCited by 7 opinions

Petitioner was a corporation engaged in the development and operation of oil leases. In 1934 it purchased several such leases with money which it borrowed from a bank. The bank required petitioner to execute deed of trust liens on the properties to secure the bank for its indebtedness and also required petitioner to execute written assignments to the bank of all proceeds from the oil produced on the leases.

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Petitioner was a corporation engaged in the development and operation of oil leases. In 1934 it purchased several such leases with money which it borrowed from a bank. The bank required petitioner to execute deed of trust liens on the properties to secure the bank for its indebtedness and also required petitioner to execute written assignments to the bank of all proceeds from the oil produced on the leases. In the taxable year all receipts from oil produced on the properties were paid to the bank and the bank in turn advanced certain amounts to petitioner to pay operating expenses and certain…

1Opinion of the Court

*741OPINION.

Black:

There is no dispute in this proceeding as to petitioner’s net income for the taxable year. Petitioner’s net income as shown on its income tax return was $36,109.32 and petitioner paid the normal tax thereon of $4,334.21, which did not include any surtax because of undistributed profits. By certain adjustments made in petitioner’s income for the taxable year, the Commissioner has determined petitioner’s corrected net income to be $38,430.31. This results in an increase of $301.73 in petitioner’s normal tax over that shown on its return. This part of the deficiency petitioner does…

2Cases cited1 opinion

  1. Hasson v. KleeSupreme Court of Pennsylvania · 1895

3Cited by7 opinions

  1. Rogan v. Walter Wanger Pictures, Inc.Court of Appeals for the Ninth Circuit · 1944
  2. Scofield v. Valley Pipe Line Co.Court of Appeals for the Fifth Circuit · 1943
  3. Brockway Glass Co. v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Corporate Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1939
  5. G. B. R. Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1939

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