Birch Ranch & Oil Co. v. Commissioner
United States Tax Court
The petitioner corporation, which kept its books on the cash basis, owned substantially all land comprised in a California reclamation district. The district had outstanding 2,000 6 per cent bonds of $ 1,000 face value each, payable from the proceeds of improvement taxes assessed against the land.
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The petitioner corporation, which kept its books on the cash basis, owned substantially all land comprised in a California reclamation district. The district had outstanding 2,000 6 per cent bonds of $ 1,000 face value each, payable from the proceeds of improvement taxes assessed against the land. The petitioner and its only shareholders, husband and wife, and holding companies wholly owned by the shareholders held 1,680 of the district's bonds at the beginning of the fiscal year 1944 and acquired 310 more about the middle of the year. To pay interest on the bonds, the reclamation district,…
1Opinion of the Court
Birch Ranch & Oil Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Birch Ranch & Oil Co. v. Commissioner
Docket No. 8720
United States Tax Court
13 T.C. 930; 1949 U.S. Tax Ct. LEXIS 16;
December 15, 1949, Promulgated
Decision will be entered under Rule 50.
The petitioner corporation, which kept its books on the cash basis, owned substantially all land comprised in a California reclamation district. The district had outstanding 2,000 6 per cent bonds of $ 1,000 face value each, payable from the proceeds of improvement taxes assessed against the land. The petitioner and its only…
2Cases cited3 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Birch Ranch & Oil Co. v. CommissionerUnited States Tax Court · 1949
- Metcalfe v. MerrittCalifornia Court of Appeal · 1910