Bankers Pocahontas Coal Co. v. Commissioner
United States Board of Tax Appeals
1. Royalties received under leases of coal lands are held to constitute gross income and not proceeds from the sale of coal in place. 2. Money received in compromise of a suit to recover the value of coal extracted by a trespasser, plus damages to the property held, on the record, to constitute taxable income. 3. Proper depletion rate per ton of coal mined determined.
1Opinion of the Court
*909OPINION.
Smith:
In these proceedings the Bankers Pocahontas Coal Co. contends that' it received no income during the taxable years and all of the moneys received as royalties were in part payment of coal in place which had been sold prior to March 1, 1913; that the typical contract quoted in part in the findings of fact constituted a sale of coal in place made before March 1, 1913, under the laws of West Virginia, and that on March 1,1913, the petitioner held only a chose in action from which no taxable income was subsequently received; that leasing agreements similar to those involved in these…
2Cases cited11 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- Stratton's Independence, Ltd. v. HowbertSupreme Court of the United States · 1913
- Stanton v. Baltic Mining Co.Supreme Court of the United States · 1916
- United States v. RindskopfSupreme Court of the United States · 1882
6 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Crossett Timber & Development Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Sugar Creek Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Bankers Pocahontas Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Baptist v. CommissionerUnited States Tax Court · 1990
- Crossett Timber & Development Co. v. CommissionerUnited States Board of Tax Appeals · 1934
2 more not listed; retrieve them via the Exa API.