Legal Opinion
Standard Oil Company (Indiana) v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided July 12, 1972No. 71-1170PublishedCited by 8 opinions
1Opinion of the Court
STEVENS, Circuit Judge.
Taxpayer contends that its receipts of $597,596.49 and $606,122.22 in 1958 and 1959, respectively, were taxable as proceeds of sale, subject to capital gains treatment, rather than as income subject to a depletion allowance. The payments were made on account of a potential obligation of up to $134,619,089.76, payable, without interest, over an indeterminate period of time according to formulas based upon the production of gas from certain interests which the taxpayer conveyed to the obligor in 1955. The tax treatment of the payments depends on whether taxpayer retained…
2Cases cited12 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. BrownSupreme Court of the United States · 1965
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
7 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Brountas v. CommissionerUnited States Tax Court · 1979
- Paul P. Brountas v. Commissioner of Internal Revenue, Paul P. And Lynn T. Brountas v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1982
- Gibson Products Co. Kell Blvd. v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Gammill v. CommissionerUnited States Tax Court · 1974
- Crooks v. CommissionerUnited States Tax Court · 1989
3 more not listed; retrieve them via the Exa API.