Pleasanton Gravel Co. v. Commissioner
United States Tax Court
T Corp. entered into a contract under which J Co. had the right to remove sand and gravel from T Corp.'s property, and which, as construed herein, did not require it to remove all or any specified portion thereof. J Co. undertook to pay for the sand and gravel removed at a price per ton geared to the wholesale selling price of sand and gravel then prevailing in the local market during the month such sand and gravel was removed.
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T Corp. entered into a contract under which J Co. had the right to remove sand and gravel from T Corp.'s property, and which, as construed herein, did not require it to remove all or any specified portion thereof. J Co. undertook to pay for the sand and gravel removed at a price per ton geared to the wholesale selling price of sand and gravel then prevailing in the local market during the month such sand and gravel was removed. Held, T Corp. did not sell its minerals "in place" but rather received royalty payments which constituted personal holding company income on account of which T Corp.…
1Opinion of the Court
Pleasanton Gravel Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Pleasanton Gravel Co. v. Commissioner
Docket No. 6095-73
United States Tax Court
64 T.C. 510; 1975 U.S. Tax Ct. LEXIS 120;
June 30, 1975, Filed
Decision will be entered for the respondent.
T Corp. entered into a contract under which J Co. had the right to remove sand and gravel from T Corp.'s property, and which, as construed herein, did not require it to remove all or any specified portion thereof. J Co. undertook to pay for the sand and gravel removed at a price per ton geared to the wholesale selling price of…
2Cases cited47 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
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