Legal Opinion

Robinson v. Commissioner

United States Board of Tax Appeals

Decided October 11, 1927No. Docket No. 7398Published

In the development of a coal mine acquired subsequent to March 1, 1913, the petitioner found after carrying on mining operations that the coal deposit was more valuable than was known to exist at the date of purchase. Held, that the petitioner is not entitled to revalue the estimated coal content and to base a depletion deduction upon such enhanced value rather than on the cost.

1Opinion of the Court

CLARENCE D. ROBINSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Robinson v. Commissioner

Docket No. 7398.

United States Board of Tax Appeals

8 B.T.A. 778; 1927 BTA LEXIS 2803;

October 11, 1927, Promulgated

In the development of a coal mine acquired subsequent to March 1, 1913, the petitioner found after carrying on mining operations that the coal deposit was more valuable than was known to exist at the date of purchase. Held, that the petitioner is not entitled to revalue the estimated coal content and to base a depletion deduction upon such enhanced value rather than on the cost.

2Cases cited2 opinions

  1. Raisbeck v. AnthonyWisconsin Supreme Court · 1889
  2. Robinson v. CommissionerUnited States Board of Tax Appeals · 1927

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