Nordan v. Commissioner
United States Tax Court
Deduction -- Contribution -- Oil and Gas -- Undivided Interest in Minerals in Place Until Production Equaled a Stated Amount -- Sec. 23 (o), I. R. C., 1939. -- A transfer by deed of oil, gas, and minerals in place to a church until $ 115,000 would be received from production was a gift and its fair market value at the date of transfer was a contribution deductible under section 23 (o) of the Internal Revenue Code of 1939 for the year of the transfer even though payments from…
Read the full summary
Deduction -- Contribution -- Oil and Gas -- Undivided Interest in Minerals in Place Until Production Equaled a Stated Amount -- Sec. 23 (o), I. R. C., 1939. -- A transfer by deed of oil, gas, and minerals in place to a church until $ 115,000 would be received from production was a gift and its fair market value at the date of transfer was a contribution deductible under section 23 (o) of the Internal Revenue Code of 1939 for the year of the transfer even though payments from production were not available until the next year.
1Opinion of the Court
OPINION.
Muedock, Judge:
The only issue for decision is whether the Commissioner erred in disallowing a deduction of $111,925.95 claimed under section 23 (o) of the Internal Revenue Code of 1939 as a contribution to a church. The facts have been presented by a stipulation which is adopted as the findings of fact.
The petitioners, husband and wife, filed a joint income tax return for 1949 with the collector of internal revenue at Austin, Texas.
The petitioners, oil and gas operators, owned, developed, and operated certain oil properties under two oil and gas leases. They executed a deed of gift on…
2Cases cited6 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Lum v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1945
- Lee v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
- Ortiz Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1939
- United States v. First Nat. Bank of BirminghamCourt of Appeals for the Fifth Circuit · 1934
1 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Fleming v. CommissionerUnited States Tax Court · 1955
- Rogers v. CommissionerUnited States Tax Court · 1962
- Friedman v. CommissionerUnited States Tax Court · 1963
- Hawn v. CommissionerUnited States Tax Court · 1954
- Threlfall v. United StatesDistrict Court, W.D. Wisconsin · 1969
14 more not listed; retrieve them via the Exa API.