Legal Opinion

H. M. Harrington, Jr. And Marguerite Harrington v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided December 3, 1968No. 25873_1PublishedCited by 20 opinions

1Opinion of the Court

ROBERTS, District Judge:

Appellants appeal from the Tax Court’s Opinion substantially affirming a ruling by the Internal Revenue Commissioner that appellants could not take a depletion allowance for the years 1959-61 on oil taken from slant-hole wells. The basis of the Commissioner’s ruling was that appellants had no “economic interest” in oil pumped from a neighbor’s lease through slanted wells. We affirm.

Appellants first challenge the Tax Court’s ruling that they did not have the necessary "economic interest” in the oil pumped from wells drilled on their leases, but bottomed on neighboring…

2Cases cited8 opinions

  1. Palmer v. BenderSupreme Court of the United States · 1932
  2. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  3. Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
  4. Kirby Petroleum Co. v. CommissionerSupreme Court of the United States · 1946
  5. Harrington v. Railroad CommissionTexas Supreme Court · 1964

3 more not listed; retrieve them via the Exa API.

3Cited by20 opinions

  1. Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
  2. Jean D. Reichenbach, a Single Woman v. David H. Smith, Michael C. Bark and State Farm Fire& Casualty Co.Court of Appeals for the Fifth Circuit · 1976
  3. Hudock v. CommissionerUnited States Tax Court · 1975
  4. Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
  5. Estate of Meyer v. CommissionerUnited States Tax Court · 1972

15 more not listed; retrieve them via the Exa API.

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