Sugar Creek Coal & Mining Co. v. Commissioner
United States Board of Tax Appeals
Where advance mining royalties are not included in gross income in the years in which received by reason of the fact that they were credited to a reserve account, and the statute of limitations has operated against the assessment and collection of the deficiencies for such years, and they are taken into the profit and loss account of the taxable year, held that the taxpayer is estopped to deny that they constitute taxable income of the year in which credited to the profit…
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Where advance mining royalties are not included in gross income in the years in which received by reason of the fact that they were credited to a reserve account, and the statute of limitations has operated against the assessment and collection of the deficiencies for such years, and they are taken into the profit and loss account of the taxable year, held that the taxpayer is estopped to deny that they constitute taxable income of the year in which credited to the profit and loss account.
1Opinion of the Court
THE SUGAR CREEK COAL AND MINING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Sugar Creek Coal & Mining Co. v. Commissioner
Docket No. 73758.
United States Board of Tax Appeals
30 B.T.A. 420; 1934 BTA LEXIS 1328;
April 18, 1934, Promulgated
Where advance mining royalties are not included in gross income in the years in which received by reason of the fact that they were credited to a reserve account, and the statute of limitations has operated against the assessment and collection of the deficiencies for such years, and they are taken into the profit and loss account of the…
2Cases cited12 opinions
- Davis v. WakeleeSupreme Court of the United States · 1895
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Casey v. GalliSupreme Court of the United States · 1877
- Commissioner of Internal Revenue v. Liberty Bank & Trust Co.Court of Appeals for the Sixth Circuit · 1932
- Miller v. GearinCourt of Appeals for the Ninth Circuit · 1919
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