Legal Opinion
Commissioner of Internal Rev. v. Jamison Coal & Coke Co.
Court of Appeals for the Third Circuit
Decided September 29, 1933No. 5047-5050PublishedCited by 21 opinions
1Opinion of the Court
DAVES, Circuit Judge.
There are four petitions here to review orders of the Board of Tax Appeals involving income and profits taxes for 1918 and 1920. 24 B. T. A. 554. Two petitions were filed by the Commissioner of Internal Revenue and two by the taxpayer, the Jamison. Coal & Coke Company of Pennsylvania.
The issue in the several petitions is whether or not annual minimum royalty payments made by the taxpayer, the lessee, under two coal leases are capital or business expenses.
The first lease is called the Thaw lease. It is for a term of forty years from 1918, and provides for royalties at a…
2Cases cited5 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- Burnet v. Hutchinson Coal Co.Court of Appeals for the Fourth Circuit · 1933
- Jefferson Gas Coal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931
- Strother v. BurnetSupreme Court of the United States · 1932
3Cited by21 opinions
- Surloff v. CommissionerUnited States Tax Court · 1983
- Wendland v. CommissionerUnited States Tax Court · 1982
- Helvering v. Russian Finance & Construction CorporationCourt of Appeals for the Second Circuit · 1935
- Seaman v. CommissionerUnited States Tax Court · 1985
- Davis v. CommissionerUnited States Tax Court · 1980
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