Fell v. Commissioner
United States Board of Tax Appeals
1. The petitioner acquired a one-fourth interest in an oil lease. Oil was not found in paying quantities, and the petitioner and his associates, within the taxable year, withdrew from the premises, removed all of their tools and equipment therefrom, and did not again enter upon the land or assert any rights therein.
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1. The petitioner acquired a one-fourth interest in an oil lease. Oil was not found in paying quantities, and the petitioner and his associates, within the taxable year, withdrew from the premises, removed all of their tools and equipment therefrom, and did not again enter upon the land or assert any rights therein. Held, the oil lease rights were abandoned in the taxable year. 2. The tools and equipment were sold and delivery made within the year, although the price to be paid was not arrived at and payment not made until subsequently. Held, the enterprise was wound up within the taxable…
1Opinion of the Court
A. H. FELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE. RESPONDENT.
Fell v. Commissioner
Docket No. 2089.
United States Board of Tax Appeals
7 B.T.A. 263; 1927 BTA LEXIS 3224;
June 9, 1927, Promulgated
1. The petitioner acquired a one-fourth interest in an oil lease. Oil was not found in paying quantities, and the petitioner and his associates, within the taxable year, withdrew from the premises, removed all of their tools and equipment therefrom, and did not again enter upon the land or assert any rights therein. Held, the oil lease rights were abandoned in the taxable year.
2. The tools and…
2Cases cited11 opinions
- Grubb v. McAfeeTexas Supreme Court · 1919
- Sult v. A. Hochstetter Oil Co.West Virginia Supreme Court · 1908
- Robinson v. JacobsTexas Supreme Court · 1923
- J. M. Guffey Petroleum Co. v. Jeff Chaison Townsite Co.Court of Appeals of Texas · 1908
- Conkling v. KranduskyAppellate Division of the Supreme Court of the State of New York · 1908
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