Ohio & Big Sandy Coal Co. v. Commissioner
United States Board of Tax Appeals
1. March 1, 1913, value of certain coal lands determined. 2. Where corporations were affiliated for excess-profits-tax purposes for a fractional part of 1917, but occupy a nonaffiliated status for the remainder of the year, the income tax may not be computed upon the basis of such fractional period, but must be computed upon the basis of a full taxable year. 3. In computing the excess-profits credit for a consolidated group for 1917 only one specific exemption of $3,000 is…
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1. March 1, 1913, value of certain coal lands determined. 2. Where corporations were affiliated for excess-profits-tax purposes for a fractional part of 1917, but occupy a nonaffiliated status for the remainder of the year, the income tax may not be computed upon the basis of such fractional period, but must be computed upon the basis of a full taxable year. 3. In computing the excess-profits credit for a consolidated group for 1917 only one specific exemption of $3,000 is allowable and not an exemption of $3,000 for each corporation which is a member of the group. 4. The provision in section…
1Opinion of the Court
*282OPINION.
Littleton:
The major issue presented in this case is the fair market price or value on March 1,1913, of certain undeveloped coal property owned by the United Thacker Coal Co. on that date and sold by it on September 17, 1917. The Commissioner determined that the March 1,1913, value of the entire property sold (including coal, sur*283face and timber lands) was $4,179,537 and that the difference between this amount and the net amount received for the property, $5,569,200 ($6,903,000 less commissions, attorney’s fees, etc., of approximately $1,333,000) constituted taxable income. The…
2Cases cited5 opinions
- Dowagiac Manufacturing Co. v. Minnesota Moline Plow Co.Supreme Court of the United States · 1915
- United Fuel Gas Co. v. Railroad CommissionSupreme Court of the United States · 1929
- Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
- Christie v. PattonSupreme Court of Alabama · 1906
- American Linseed Co. v. EbersonMissouri Court of Appeals · 1907
3Cited by5 opinions
- American Textile Woolen Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Estate of Ballas v. CommissionerUnited States Tax Court · 1975
- Ohio & Big Sandy Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Pittsburgh & W. Va. Ry. v. CommissionerUnited States Board of Tax Appeals · 1935
- Union Pac. R.R. v. CommissionerUnited States Board of Tax Appeals · 1929