Texasgulf, Inc. v. Commissioner
United States Tax Court
1. The concession granted to a Mexican subsidiary of the taxpayer to mine sulphur by the Mexican Government provided for the payment of a "royalty" measured by the then market value of the sulphur as the sulphur was mined. Subsequently, payment of a part of this royalty was deferred until the sulphur was sold. HELD: The liability for the payment of the royalty accrued when the sulphur was mined, notwithstanding there were no sales of the sulphur.
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1. The concession granted to a Mexican subsidiary of the taxpayer to mine sulphur by the Mexican Government provided for the payment of a "royalty" measured by the then market value of the sulphur as the sulphur was mined. Subsequently, payment of a part of this royalty was deferred until the sulphur was sold. HELD: The liability for the payment of the royalty accrued when the sulphur was mined, notwithstanding there were no sales of the sulphur. The amount thus accrued could be charged to inventory in the year that the sulphur was mined. Washington Post Company v. United States,405 F.2d 1279…
1Opinion of the Court
TEXASGULF INC. and SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Texasgulf, Inc. v. Commissioner
Docket No. 7950-71.
United States Tax Court
T.C. Memo 1976-39; 1976 Tax Ct. Memo LEXIS 364; 35 T.C.M. (CCH) 158; T.C.M. (RIA) 760039;
February 12, 1976, Filed
1. The concession granted to a Mexican subsidiary of the taxpayer to mine sulphur by the Mexican Government provided for the payment of a "royalty" measured by the then market value of the sulphur as the sulphur was mined. Subsequently, payment of a part of this royalty was deferred until the sulphur was sold. HELD: The…
2Cases cited13 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Boehm v. CommissionerSupreme Court of the United States · 1945
- W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
- A. J. Industries, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1974
- Thor Power Tool Co. v. CommissionerUnited States Tax Court · 1975
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Energy Resources Ltd. Partnership v. CommissionerUnited States Tax Court · 1992