Legal Opinion

Gardner v. Commissioner

United States Tax Court

Decided November 9, 1976No. Docket No. 4603-73UnpublishedCited by 2 opinions

Petitioner entered into an oil and gas drilling program under which he agreed to pay $13,500 to Drilling Co. for drilling a well on a location assigned to him under a lease held by Transmission Co., an affiliate of the drilling company.At the time of entering into two such contracts in 1968 and two in 1969, petitioner made a cash downpayment of $2,700 and purportedly borrowed $10,800 from Leasing Co., a parent of Transmission Co., to pay Drilling Co. the balance due on the…

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Petitioner entered into an oil and gas drilling program under which he agreed to pay $13,500 to Drilling Co. for drilling a well on a location assigned to him under a lease held by Transmission Co., an affiliate of the drilling company.At the time of entering into two such contracts in 1968 and two in 1969, petitioner made a cash downpayment of $2,700 and purportedly borrowed $10,800 from Leasing Co., a parent of Transmission Co., to pay Drilling Co. the balance due on the drilling contract. There is no evidence that wells were drilled or reworked on the specific locations assigned to…

1Opinion of the Court

DALE L. GARDNER AND EMMA J. GARDNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Gardner v. Commissioner

Docket No. 4603-73

United States Tax Court

T.C. Memo 1976-337; 1976 Tax Ct. Memo LEXIS 66; 35 T.C.M. (CCH) 1546; T.C.M. (RIA) 760337; 55 Oil & Gas Rep. 395;

November 9, 1976, Filed

Petitioner entered into an oil and gas drilling program under which he agreed to pay $13,500 to Drilling Co. for drilling a well on a location assigned to him under a lease held by Transmission Co., an affiliate of the drilling company.At the time of entering into two such contracts in 1968 and two in…

2Cases cited10 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. United States v. PowellSupreme Court of the United States · 1964
  4. Roberts v. CommissionerUnited States Tax Court · 1974
  5. Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956

5 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Stradlings Bldg. Materials, Inc. v. CommissionerUnited States Tax Court · 1981
  2. Stradlings Bldg. Materials, Inc. v. CommissionerUnited States Tax Court · 1981

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