Legal Opinion

Sabine Royalty Corp. v. Commissioner

United States Tax Court

Decided December 29, 1951No. Docket No. 25149Published

1. Interest. -- Petitioner, a corporation engaged in the business of investing in oil properties, issued income debentures in exchange for its own stock.

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1. Interest. -- Petitioner, a corporation engaged in the business of investing in oil properties, issued income debentures in exchange for its own stock. Held, interest payments on such debentures are deductible under section 23 (b), I. R. C. 2. Depletion. -- Petitioner increased the 1947 cost basis of its royalty interests by the excess of cost depletion deductions over percentage depletion deductions for the years 1933 to 1939 when percentage depletion had been claimed for those years. Held, increase to cost basis in the years before us improper and depletion determined from the increased…

1Opinion of the Court

Sabine Royalty Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Sabine Royalty Corp. v. Commissioner

Docket No. 25149

United States Tax Court

17 T.C. 1071; 1951 U.S. Tax Ct. LEXIS 2;

December 29, 1951, Promulgated

Decision will be entered under Rule 50.

1. Interest. -- Petitioner, a corporation engaged in the business of investing in oil properties, issued income debentures in exchange for its own stock. Held, interest payments on such debentures are deductible under section 23 (b), I. R. C.

2. Depletion. -- Petitioner increased the 1947 cost basis of its royalty interests by…

2Cases cited8 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
  4. Pierce Estates, Inc. v. CommissionerUnited States Tax Court · 1951
  5. Helvering v. Virginian Hotel CorporationCourt of Appeals for the Fourth Circuit · 1943

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