Legal Opinion

Thompson v. Commissioner

United States Board of Tax Appeals

Decided January 19, 1928No. Docket No. 17452PublishedCited by 10 opinions

One who acquires, in the year 1921, by gift, an interest in an oil lease on a proven tract is not entitled to discovery value for depletion purposes.

1Opinion of the Court

*26OPINION.

Milliken :

The facts were stipulated and our findings of fact are in exact accordance with the stipulation. Section 214 of the Revenue Act of 1921, in part reads:

*27Sec. 214. (a) That in computing net income there shall be allowed as deductions :

*******(10) In the case of mines, oil and gas wells, other natural deposits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost including cost of development not otherwise deducted: Provided, That in the case of such properties acquired prior to…

2Cited by10 opinions

  1. Alamo Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Champlin v. CommissionerUnited States Board of Tax Appeals · 1934
  3. Daniel v. CommissionerUnited States Board of Tax Appeals · 1929
  4. Darby-Lynde Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Hoyt v. CommissionerUnited States Board of Tax Appeals · 1936

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