Standard Oil Co. v. Commissioner
United States Tax Court
In 1955 T assigned gas rights in certain oil and gas leases in return for annual payments based on the volume of actual or possible gas production. Apart from a cash payment for physical equipment and facilities, T received no present consideration and looked solely to the deferred annual payments in respect of gas production or potential gas production as consideration for the gas reserves themselves.
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In 1955 T assigned gas rights in certain oil and gas leases in return for annual payments based on the volume of actual or possible gas production. Apart from a cash payment for physical equipment and facilities, T received no present consideration and looked solely to the deferred annual payments in respect of gas production or potential gas production as consideration for the gas reserves themselves. No limit was placed on the amount of such payments, and the assignee was not permitted to sell any of the assigned gas rights without the consent of T. In 1958 the parties modified the…
1Opinion of the Court
Standard Oil Company (Indiana), Petitioner v. Commissioner of Internal Revenue, Respondent
Standard Oil Co. v. Commissioner
Docket No. 3613-68
United States Tax Court
54 T.C. 1099; 1970 U.S. Tax Ct. LEXIS 128; 36 Oil & Gas Rep. 332;
May 27, 1970, Filed
Decision will be entered under Rule 50.
In 1955 T assigned gas rights in certain oil and gas leases in return for annual payments based on the volume of actual or possible gas production. Apart from a cash payment for physical equipment and facilities, T received no present consideration and looked solely to the deferred annual payments in respect of…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Burnet v. HarmelSupreme Court of the United States · 1932
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Palmer v. BenderSupreme Court of the United States · 1932
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