Kern Oil Co. v. Commissioner
United States Tax Court
British income taxes of British corporation operating oil-producing properties in United States, held properly deducted in computing 50 per cent of net income from the oil properties for purposes of determining limitation on percentage depletion under Internal Revenue Code, section 114 (b) (3).
1Opinion of the Court
OPINION.
Opper, Judge-.
This proceeding involves a deficiency in income tax for the fiscal year ended May 81,1941, in the amount of $440.38. •
The issue is the propriety of respondent’s action in deducting a portion of British income and national defense contribution taxes from petitioner’s gross income from oil properties, in computing the limitation on percentage depletion pursuant to Internal Revenue Code, section 114 (b) (3).
All of the material facts have been stipulated or admitted in the pleadings, and are hereby found accordingly. For purposes of this proceeding they may be summarized as…
2Cases cited3 opinions
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
- Montreal Mining Co. v. CommissionerUnited States Tax Court · 1943
3Cited by3 opinions
- Appeal of Producers Pipe & Supply Co. v. State Commission of Revenue & TaxationSupreme Court of Kansas · 1956
- Kern Oil Co. v. CommissionerUnited States Tax Court · 1947
- New York City Omnibus Corp. v. CommissionerUnited States Tax Court · 1948