Weinert v. Commissioner
United States Tax Court
Petitioner sold a one-half undivided interest in certain unitized oil and gas leases and a $ 50,000 production payment, payable out of the income from petitioner's retained one-half interest in the leases, to Lehman and Maracaibo for $ 100,000 cash in 1947. At the same time Lehman and Maracaibo agreed to loan and advance up to $ 150,000 to pay petitioner's pro rata share of drilling and recycling plant costs under the unitization agreements.
Read the full summary
Petitioner sold a one-half undivided interest in certain unitized oil and gas leases and a $ 50,000 production payment, payable out of the income from petitioner's retained one-half interest in the leases, to Lehman and Maracaibo for $ 100,000 cash in 1947. At the same time Lehman and Maracaibo agreed to loan and advance up to $ 150,000 to pay petitioner's pro rata share of drilling and recycling plant costs under the unitization agreements. Petitioner assigned his retained one-half interest in the lease and the proceeds attributable thereto under the unitization agreements to a trustee, the…
1Opinion of the Court
OPINION.
Drennen, Judge:
Respondent determined deficiencies in petitioners’ income tax of $817.31 and $4,193.86, for the calendar years 1949 and 1950, respectively. In their petition, petitioners seek a determination that there have been overassessments of $1,399.06 and $7,987.30 for the years 1949 and 1950, although the basis for the claimed overassessments is not clear.
The sole issue raised by the pleadings is whether petitioners were taxable on revenues from their interest in certain oil and gas leases and a recycling plant, received by a trustee under an assignment thereof, in the years…
2Cases cited10 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Anderson v. HelveringSupreme Court of the United States · 1940
- Manahan Oil Co. v. CommissionerUnited States Tax Court · 1947
- Wood v. CommissionerUnited States Tax Court · 1958
5 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Estate of H. H. Weinert, Deceased, Jane W. Blumberg, and Hilda B. Weinert v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- Estate of Durkin v. CommissionerUnited States Tax Court · 1992
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- Callahan Mining Corp. v. CommissionerUnited States Tax Court · 1969
22 more not listed; retrieve them via the Exa API.