Rainbow Gasoline Corp. v. Commissioner
United States Board of Tax Appeals
1. DEPLETION - CASINGHEAD GAS. - Where petitioner, who was the owner of casinghead gas contracts and engaged in the manufacture or extraction of gasoline from such gas, paid royalties equal to the full fair market value of the gas at the wells, held, there is no basis under section 114(b)(3), Revenue Act of 1928, for the computation of percentage depletion deductions, nor deductions based upon cost, since there is no proof petitioner paid anything for the contracts in excess…
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1. DEPLETION - CASINGHEAD GAS. - Where petitioner, who was the owner of casinghead gas contracts and engaged in the manufacture or extraction of gasoline from such gas, paid royalties equal to the full fair market value of the gas at the wells, held, there is no basis under section 114(b)(3), Revenue Act of 1928, for the computation of percentage depletion deductions, nor deductions based upon cost, since there is no proof petitioner paid anything for the contracts in excess of royalties. Helvering v. Twin Bell Oil Syndicate,293 U.S. 312; Signal Gasoline Corporation,30 B.T.A. 568; Greensboro…
1Opinion of the Court
OPINION.
Teammell:
These are consolidated proceedings for the rede-termination of income taxes for the years 1929 and 1930 in the amounts of $1,119.22 and $6,162.93, respectively. The issues are: (1) Whether limitations barred assessment and collection of the deficiencies at the dates of mailing of the deficiency notices; (2) whether petitioner is entitled to deductions for depletion of casing-head gas; (3) whether petitioner is entitled to compute deductions for depreciation on the unit of production basis; (4) whether certain expenditures in the taxable year constituted capital investments or…
2Cases cited1 opinion
- Helvering v. Twin Bell Oil SyndicateSupreme Court of the United States · 1934
3Cited by9 opinions
- Dean v. CommissionerUnited States Tax Court · 1961
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- H. S. D. Co. v. Kavanagh, Collector of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
- Winter v. United StatesUnited States Court of Claims · 1991
- Ace Heater Mfg. Co. v. CommissionerUnited States Tax Court · 1951
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