Legal Opinion
Tidewater Oil Co. v. United States
United States Court of Claims
Decided December 11, 1964No. 30-61PublishedCited by 17 opinions
1Opinion of the CourtLaramore, Judge
This is a suit for refund of Federal income taxes for the year 1952 in which the ultimate question presented is whether the amounts paid by taxpayer to transferors of “oil allow-ables” constitute royalties so that, under section 114(b) (3)1 of the Internal Kevenue Code of 1939, such payments must be excluded from gross income before computing taxpayer’s depletion allowance. The answer to this question depends on whether the assignors of the allowables had a depletable “economic interest” in the oil in place with respect to the oil produced under these allowables. Taxpayer asserts it is the…
2Cases cited9 opinions
- Burford v. Sun Oil Co.Supreme Court of the United States · 1943
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- 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
- Cbn Corporation (Formerly Columbian Carbon Company) v. The United StatesCourt of Appeals for the D.C. Circuit · 1966
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
- Harrington v. CommissionerUnited States Tax Court · 1967
- Freede v. CommissionerUnited States Tax Court · 1986
12 more not listed; retrieve them via the Exa API.