Stradlings Bldg. Materials, Inc. v. Commissioner
United States Tax Court
Held, on the facts, prepaid intangible drilling expenses pursuant to a binding contract allowed despite failure of contractor to perform services in subsequent tax year.
1Opinion of the Court
OPINION
Hall, Judge:
Respondent determined a deficiency in petitioner’s 1973 Federal income tax of $30,720. The sole issue for decision is whether petitioner is entitled to an $80,003 intangible drilling expense deduction in 1973.
This case was submitted fully stipulated.
Petitioner is a corporation organized under the laws of the State of Arizona, with its principal place of business in Mesa, Ariz. Petitioner is engaged primarily in the business of cabinet building.
Petitioner maintains its books and records and files its Federal income tax returns using the accrual method of accounting and a…
2Cases cited16 opinions
- Remmer v. United StatesSupreme Court of the United States · 1954
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. FlannerySupreme Court of the United States · 1925
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Riss v. CommissionerUnited States Tax Court · 1971
11 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Keller v. CommissionerUnited States Tax Court · 1982
- Stephen A. Keller and Ethel L. Keller v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1984
- Ronald R. Levy and Esther Levy, Petitioners-Appellants/cross-Appellees v. Commissioner of Internal Revenue, Respondent-Appellee/cross-AppellantCourt of Appeals for the Ninth Circuit · 1984
- Charles J. Heitzman v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
10 more not listed; retrieve them via the Exa API.