Legal Opinion
Charles J. Heitzman v. Commissioner of the Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided October 18, 1988No. 87-7181PublishedCited by 6 opinions
1Opinion of the Court
JAMES R. BROWNING, Circuit Judge:
Charles J. Heitzman, a limited partner in Stonehurst Energy Partners, both of whom operated under the accrual method of accounting for tax purposes, deducted his share of the partnership’s obligation for advanced oil and gas royalties and for the costs of drilling oil and gas wells on his 1979 return. The Commissioner disallowed the deductions. The Tax Court upheld the Commissioner. We affirm.
I
On December 29, 1979, Stonehurst entered a sublease for land on which it planned to drill oil and gas wells. The sublease provided that Stonehurst’s obligation to pay…
2Cases cited14 opinions
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Dalton v. BowersSupreme Court of the United States · 1932
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Dickman v. CommissionerSupreme Court of the United States · 1984
- United States v. General Dynamics Corp.Supreme Court of the United States · 1987
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3Cited by6 opinions
- Apple Computer, Inc. v. CommissionerUnited States Tax Court · 1992
- Weil v. Retirement Plan Administrative CommitteeCourt of Appeals for the Second Circuit · 1991
- Weil v. Retirement Plan Administrative Committee of the Terson Co.Court of Appeals for the Second Circuit · 1991
- Apple Computer, Inc. v. CommissionerUnited States Tax Court · 1992
- Nowlin v. CommissionerUnited States Tax Court · 1992
1 more not listed; retrieve them via the Exa API.