Buckley v. Commissioner
United States Tax Court
1. Petitioners held certificates of ownership 1The terms "certificates of ownership," "units of ownership," "shares," and "stock" are used interchangeably hereinafter, as are the terms "certificate holders," "unit holders," "shareholders," and "stockholders." in two organizations formed under the laws of Venezuela as "anonymous companies" which held royalty rights to certain oil producing realty in Venezuela.
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1. Petitioners held certificates of ownership 1The terms "certificates of ownership," "units of ownership," "shares," and "stock" are used interchangeably hereinafter, as are the terms "certificate holders," "unit holders," "shareholders," and "stockholders." in two organizations formed under the laws of Venezuela as "anonymous companies" which held royalty rights to certain oil producing realty in Venezuela. Those companies had broad powers to carry on business, held title to property in their own right, had centralized management and continuity of enterprise uninterrupted by deaths among…
1Opinion of the Court
OPINION.
Arundell, Judge:
Petitioners, during the years in question, held certificates of ownership in the two “anonymous companies,” Aurora and Anzoategui, which companies had title to certain royalty rights on various parcels of oil producing property in Venezuela. The royalties were paid by the concessionaires or exploiters to Aurora and Anzoategui which companies after setting aside sufficient sums to meet administrative expenses, taxes, and necessary reserves, either as required by Venezuelan law or otherwise, distributed the balance to the holders of the certificates of ownership.
In…
2Cases cited3 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Commissioner of Internal Rev. v. Nebo Oil Co., TrustCourt of Appeals for the Tenth Circuit · 1942
3Cited by1 opinion
- Buckley v. CommissionerUnited States Tax Court · 1954