Big Four Oil & Gas Co. v. Commissioner
United States Tax Court
Excess Profits Tax -- Net Abnormal Income Attributable to Prior Years -- Sec. 456 (a) (2) (B). -- A producing "discovery" oil well or wells having been completed in an oil pool covered by petitioners' leases less than a year after the beginning of "exploration, discovery, or prospecting" by petitioners relating to the area covered by such leases, petitioners have failed to show that the income from such pool claimed to be abnormal resulted from "exploration, discovery, or…
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Excess Profits Tax -- Net Abnormal Income Attributable to Prior Years -- Sec. 456 (a) (2) (B). -- A producing "discovery" oil well or wells having been completed in an oil pool covered by petitioners' leases less than a year after the beginning of "exploration, discovery, or prospecting" by petitioners relating to the area covered by such leases, petitioners have failed to show that the income from such pool claimed to be abnormal resulted from "exploration, discovery, or prospecting" extending over a period of more than 12 months as required by the provisions of section 456 (a) (2) (B), I.…
1Opinion of the Court
OPINION.
Kern, Judge:
It is necessary to spell out with some particularity the issue in the instant case under the pleadings. The most specific allegation of error contained in the petitions is as follows (paragraph 4(h)):
The Commissioner of Internal Revenue erred in determining that petitioner did not Qualify for relief under Section 456 of the 1939 Internal Revenue Code with respect to abnormal income for 1950 resulting from exploration, discovery or prospecting, or any combination of the foregoing, extending over a period of more than 12 months.
Paragraphs 5 (b) and 5 (k) of each petition…
2Cases cited4 opinions
- Halle v. CommissionerUnited States Tax Court · 1946
- M. C. Parrish & Co. v. CommissionerUnited States Tax Court · 1944
- M. C. Parrish & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Rissman v. CommissionerUnited States Tax Court · 1946
3Cited by4 opinions
- Polaroid Corp. v. CommissionerUnited States Tax Court · 1959
- Big Four Oil & Gas Co. v. CommissionerUnited States Tax Court · 1957
- Honan v. CommissionerUnited States Tax Court · 1984
- Polaroid Corp. v. CommissionerUnited States Tax Court · 1959