Prater v. Commissioner
United States Tax Court
Petitioner, one of three lessees of certain oil properties, acquired his one-quarter of the working interest in the properties in consideration for his securing the leases and supervising the operation of the properties. The other two lessees furnished all of the original capital, and they financed the development and subsequent operation of the properties through a bank loan which they received as cosignors of a note.
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Petitioner, one of three lessees of certain oil properties, acquired his one-quarter of the working interest in the properties in consideration for his securing the leases and supervising the operation of the properties. The other two lessees furnished all of the original capital, and they financed the development and subsequent operation of the properties through a bank loan which they received as cosignors of a note. Petitioner signed a deed of trust on the properties as security for the note, but he did not sign the note and was not personally liable for the drilling and development…
1Opinion of the Court
Tkain, Judge:
Respondent determined deficiencies in income tax and an addition to tax against petitioners as follows:
Tear Addition ■ to totee Deft- sec. 29J) eiency (d)(2)
1950_ $91.00 _
1951_ 1,331.98 _
1952_ 688.60 $69.40
The issues for decision are: (1) Whether petitioners should be allowed to deduct losses from certain operating oil wells for the years 1950 and 1951 and realized income from tire properties in the year 1952; (2) whether petitioners should be allowed net operating loss carryover deductions in the years 1951 and 1952 based on net operating losses for the years 1949 and 1950; and…
2Cases cited6 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Eckert v. BurnetSupreme Court of the United States · 1931
- Commissioner of Internal Rev. v. JS Abercrombie Co.Court of Appeals for the Fifth Circuit · 1947
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Estate of H. H. Weinert, Deceased, Jane W. Blumberg, and Hilda B. Weinert v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- Farwell v. CommissionerUnited States Tax Court · 1960
- Weinert v. CommissionerUnited States Tax Court · 1959
- Carl A. Prater and Della Jane C. Prater, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Callahan Mining Corp. v. CommissionerUnited States Tax Court · 1969
5 more not listed; retrieve them via the Exa API.