Bayou Verret Land Co. v. Commissioner
United States Tax Court
In each of the years 1959 through 1963, petitioner received bonuses upon the execution of oil and gas leases, and claimed percentage depletion thereon. In each of the succeeding years, 1960 through 1964, respectively, the lease of the immediately preceding year was terminated without production, and, pursuant to sec. 1.612-3(a)(2), Income Tax Regs., petitioner returned as income a sum equal to the depletion deduction claimed for the immediately preceding year.
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In each of the years 1959 through 1963, petitioner received bonuses upon the execution of oil and gas leases, and claimed percentage depletion thereon. In each of the succeeding years, 1960 through 1964, respectively, the lease of the immediately preceding year was terminated without production, and, pursuant to sec. 1.612-3(a)(2), Income Tax Regs., petitioner returned as income a sum equal to the depletion deduction claimed for the immediately preceding year. Respondent determined that petitioner was subject to the personal holding company tax for 1959, 1960, 1961, 1963, and 1964. Held, the…
1Opinion of the Court
Bayou Verret Land Co., Inc., 1 Petitioner v. Commissioner of Internal Revenue, Respondent
Bayou Verret Land Co. v. Commissioner
Docket No. 6308-66
United States Tax Court
52 T.C. 971; 1969 U.S. Tax Ct. LEXIS 56; 34 Oil & Gas Rep. 137;
September 23, 1969, Filed
Decision will be entered under Rule 50.
In each of the years 1959 through 1963, petitioner received bonuses upon the execution of oil and gas leases, and claimed percentage depletion thereon. In each of the succeeding years, 1960 through 1964, respectively, the lease of the immediately preceding year was terminated without production, and,…
2Cases cited38 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Anderson v. HelveringSupreme Court of the United States · 1940
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
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