Hudson v. Commissioner
United States Board of Tax Appeals
In 1906, prior to the discovery of any oil thereon, petitioner and his wife acquired by purchase the fee simple title to certain lands. The land had no mineral value at the date of purchase or on March 1, 1913. In 1919 petitioner and his wife granted a mineral lease on such property retaining a one-eighth royalty interest. In 1921 oil was discovered and thereafter petitioner and his wife sold a portion of their retained royalty interest.
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In 1906, prior to the discovery of any oil thereon, petitioner and his wife acquired by purchase the fee simple title to certain lands. The land had no mineral value at the date of purchase or on March 1, 1913. In 1919 petitioner and his wife granted a mineral lease on such property retaining a one-eighth royalty interest. In 1921 oil was discovered and thereafter petitioner and his wife sold a portion of their retained royalty interest. Held, the entire amount received from the sale of such portion was income under section 202 of the Revenue Act of 1921. Appeal of Anna Taylor,3 B.T.A. 1201.
1Opinion of the Court
J. M. HUDSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hudson v. Commissioner
Docket No. 15215.
United States Board of Tax Appeals
14 B.T.A. 983; 1929 BTA LEXIS 3009;
January 3, 1929, Promulgated
In 1906, prior to the discovery of any oil thereon, petitioner and his wife acquired by purchase the fee simple title to certain lands. The land had no mineral value at the date of purchase or on March 1, 1913. In 1919 petitioner and his wife granted a mineral lease on such property retaining a one-eighth royalty interest. In 1921 oil was discovered and thereafter petitioner and his…
2Cases cited2 opinions
- Taylor v. CommissionerUnited States Board of Tax Appeals · 1926
- Hudson v. CommissionerUnited States Board of Tax Appeals · 1929