Legal Opinion
James T. Cox v. United States
Court of Appeals for the Fourth Circuit
Decided May 22, 1974No. 73-2322PublishedCited by 10 opinions
1Opinion of the Court
FIELD, Circuit Judge:
This appeal presents the question whether the retention of an overriding royalty interest incident to the assignment of certain oil and gas leases constitutes an “economic interest” which subjects the initial lump sum payments to ordinary income treatment rather than capital gains consideration.
In 1959 A. T. Carr leased 1,194 acres of oil and gas lands in Doddridge County, West Virginia, for one dollar per acre. In 1960 the appellee, James T. Cox, entered into an informal agreement with Carr under which he would contribute $2,000 for the development of a well in exchange…
2Cases cited13 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
8 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Brountas v. CommissionerUnited States Tax Court · 1979
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
- Mesa Petroleum Co. v. U.S. Department of InteriorDistrict Court, W.D. Louisiana · 1986
- Filgo v. United StatesDistrict Court, N.D. Texas · 1974
- Moore v. Tristar Oil and Gas Corp.District Court, S.D. New York · 1981
5 more not listed; retrieve them via the Exa API.