Sabine Royalty Corp. v. Commissioner
United States Tax Court
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…
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- Helvering v. Virginian Hotel CorporationCourt of Appeals for the Fourth Circuit · 1943
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