Collins v. Commissioner
United States Tax Court
Held, that portions of amounts received from two oil companies by a partnership of which petitioners were partners constituted payments for anticipated damage to leases on oyster beds from the laying of pipelines across such beds, and that no income was derived by the partnership from receipt of such portions except to the extent they exceeded the basis of the leases. The excess held to be long-term capital gain.
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Held, that portions of amounts received from two oil companies by a partnership of which petitioners were partners constituted payments for anticipated damage to leases on oyster beds from the laying of pipelines across such beds, and that no income was derived by the partnership from receipt of such portions except to the extent they exceeded the basis of the leases. The excess held to be long-term capital gain. The remaining portions of the amounts received from the oil companies held to constitute ordinary income.
1Opinion of the Court
Levy Collins, Jr., and Temirre C. Collins v. Commissioner. Levy Collins, Sr., and Amelia C. Collins v. Commissioner.
Collins v. Commissioner
Docket Nos. 70307, 70340.
United States Tax Court
T.C. Memo 1959-174; 1959 Tax Ct. Memo LEXIS 74; 18 T.C.M. (CCH) 756; T.C.M. (RIA) 59174; 11 Oil & Gas Rep. 133;
August 31, 1959
Held, that portions of amounts received from two oil companies by a partnership of which petitioners were partners constituted payments for anticipated damage to leases on oyster beds from the laying of pipelines across such beds, and that no income was derived by the partnership from…
2Cases cited12 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Hort v. CommissionerSupreme Court of the United States · 1941
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
- Fuller v. CommissionerUnited States Tax Court · 1953
- Smith v. CommissionerUnited States Tax Court · 1953
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