Legal Opinion
Kenneth Whitmer and Beatrice Whitmer v. Commissioner of Internal Revenue. William E. Heitzman and Mary Heitzman v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided May 20, 1971No. 19201, 19202PublishedCited by 18 opinions
1Opinion of the Court
OPINION OF THE COURT
ADAMS, Circuit Judge.
The sole question presented on this appeal is whether the Tax Court erred in finding that the taxpayers do not have a sufficient “economic interest” in a certain anthracite coal lease in Northumberland County, Pennsylvania to qualify for the depletion deduction allowed by §§ 611 and 613 of the Internal Revenue Code of 1954 (“the Code”), 26 U.S.C. §§ 611, 613.
For the most part, the facts in this ease are not in dispute; rather the parties disagree principally with regard to the legal inferences which must be drawn from the facts. On February 11, 1952,…
2Cases cited12 opinions
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Parsons v. SmithSupreme Court of the United States · 1959
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
- Shenandoah Borough v. PhiladelphiaSupreme Court of Pennsylvania · 1951
- United States v. James C. And Helen M. Stallard, and Dewey H. And Geneva StallardCourt of Appeals for the Fourth Circuit · 1959
7 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Coleman v. CommissionerUnited States Tax Court · 1986
- Ridder v. CommissionerUnited States Tax Court · 1981
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Weaver v. CommissionerUnited States Tax Court · 1979
- Bakertown Coal Co. v. United StatesUnited States Court of Claims · 1973
13 more not listed; retrieve them via the Exa API.