Legal Opinion

Ferguson v. Commissioner

United States Board of Tax Appeals

Decided June 24, 1930No. Docket No. 34975Published

1. Amounts paid to the grantor of an oil and gas lease as royalties and as bonuses held taxable as income at the ordinary rates and not as capital gain. 2. Royalties and bonuses received by a resident of Texas from oil and gas leases covering his separately owned land located in Texasheld to be his separate income. 3. Petitioner's earned-income credit for 1924 and 1925 determined.

1Opinion of the Court

W. P. FERGUSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ferguson v. Commissioner

Docket No. 34975.

United States Board of Tax Appeals

20 B.T.A. 130; 1930 BTA LEXIS 2199;

June 24, 1930, Promulgated

1. Amounts paid to the grantor of an oil and gas lease as royalties and as bonuses held taxable as income at the ordinary rates and not as capital gain.

2. Royalties and bonuses received by a resident of Texas from oil and gas leases covering his separately owned land located in Texasheld to be his separate income.

3. Petitioner's earned-income credit for 1924 and 1925 determined.

Robert…

2Cases cited15 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
  3. Stratton's Independence, Ltd. v. HowbertSupreme Court of the United States · 1913
  4. New York Ex Rel. Bryant v. ZimmermanSupreme Court of the United States · 1928
  5. Stanton v. Baltic Mining Co.Supreme Court of the United States · 1916

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