Louisiana Land & Exploration Co. v. Commissioner
United States Tax Court
1. Held, petitioner is entitled to a deduction for depletion on its share of net profits from a lessee's drilling operations on oil and gas leases.
Read the full summary
1. Held, petitioner is entitled to a deduction for depletion on its share of net profits from a lessee's drilling operations on oil and gas leases. Kirby Petroleum Co. v. Commissioner, 326 U.S. 599. 2. In 1939 petitioner instituted suit in a Federal District Court to quiet title to land on which in 1928 petitioner had given an oil and gas lease to the Texas Co. In January 1940 Texas Co. obtained an oil and gas lease on this land from the title claimants, paying therefor $ 25,000. In June 1940 petitioner reimbursed Texas for the $ 25,000 payment and Texas agreed to assign to petitioner the…
1Opinion of the Court
OPINION.
Hill, Judge:
Issue 1. — As is conceded by respondent on brief, the depletion issue involves the same type of payment to this petitioner under the same contract as was considered with respect to the years 1939 and 1940 in Louisiana Land & Exploration Co., 6 T. C. 172. In that proceeding, the opinion in which was promulgated after this case was submitted, we sustained this petitioner’s deduction of percentage depletion on such payment on the authority of Kirby Petroleum, Co. v. Commissioner, 326 U. S. 599. We accordingly hold here that petitioner properly deducted as depletion in 1941…
2Cases cited7 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Thomas v. PerkinsSupreme Court of the United States · 1937
- Kirby Petroleum Co. v. CommissionerSupreme Court of the United States · 1946
- Harmon v. CommissionerUnited States Tax Court · 1942
2 more not listed; retrieve them via the Exa API.
3Cited by73 opinions
- Brountas v. CommissionerUnited States Tax Court · 1979
- Cagle v. CommissionerUnited States Tax Court · 1974
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
- Edward R. Godfrey and Georgia G. Godfrey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
68 more not listed; retrieve them via the Exa API.