Legal Opinion

Cooper v. Commissioner

United States Tax Court

Decided October 31, 1962No. Docket Nos. 70456, 70457, 70528Published

1. Held, the petitioners are not entitled to depletion deductions for coal they mined under oral agreements with the lessee of land containing coal. 2. Held, further, the petitioners at Docket No. 70456 failed to show that they are not subject to the penalty for failure to file a declaration of estimated tax for the year 1953.

1Opinion of the Court

Raymond E. Cooper and Judy Cooper, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Cooper v. Commissioner

Docket Nos. 70456, 70457, 70528

United States Tax Court

39 T.C. 253; 1962 U.S. Tax Ct. LEXIS 39;

October 31, 1962, Filed

Decisions will be entered under Rule 50.

1. Held, the petitioners are not entitled to depletion deductions for coal they mined under oral agreements with the lessee of land containing coal.

2. Held, further, the petitioners at Docket No. 70456 failed to show that they are not subject to the penalty for failure to file a declaration of estimated tax for…

2Cases cited7 opinions

  1. Parsons v. SmithSupreme Court of the United States · 1959
  2. United States v. James C. And Helen M. Stallard, and Dewey H. And Geneva StallardCourt of Appeals for the Fourth Circuit · 1959
  3. Bolling v. CommissionerUnited States Tax Court · 1962
  4. McCall v. CommissionerUnited States Tax Court · 1962
  5. Legg v. CommissionerUnited States Tax Court · 1962

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