Ingle Coal Corp. v. United States

The plaintiff, a corporation, sues for $32,289.85, with interest thereon, which represents alleged overpayments of Federal income taxes for 1947 and 1948. The issue presented is whether certain “over-riding royalties” paid by plaintiff in 1947 and 1948 are deductible as ordinary and necessary expenses under section 23 (a) (1) (A) of the Internal Revenue Code, (26 U. S. C. Sec. 23 (a)). The facts have been stipulated and those material may be summarized as follows: The Ingle Coal Company, plaintiff’s predecessor, (hereinafter sometimes referred to as the old corporation) was a family…