State Consol. Oil Co. v. Commissioner of Internal Rev.

MACK, Circuit Judge.

Petitioner seeks review of an order of the Board of Tax Appeals sustaining the Commissioner’s rejection of its claim for a certain refund. The claim resulted from the filing of amended returns for 1920 and 1921 in which it was asserted that certain expenditures for those years, originally charged to accounts receivable, should be allowed as deductions.

The expenditures were made in connection with oil well drilling operations under a contract by the terms of which petitioner was to drill wells on two lots belonging to the other party to the contract; the proceeds resulting…