Linebery v. Commissioner
United States Tax Court
Held, petitioners' monthly receipts, measured by a percentage of the amounts received by Shell Oil Co. from the sale of water transported through pipelines laid on right-of-way across petitioners' land, are taxable as ordinary income. Held, further, amounts received by petitioners from the extraction of caliche under terminable agreements calling for payments measured by production are taxable as ordinary income.
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Held, petitioners' monthly receipts, measured by a percentage of the amounts received by Shell Oil Co. from the sale of water transported through pipelines laid on right-of-way across petitioners' land, are taxable as ordinary income. Held, further, amounts received by petitioners from the extraction of caliche under terminable agreements calling for payments measured by production are taxable as ordinary income. Held, further, value of a lot and building contributed to an exempt educational organization determined.
1Opinion of the Court
Tom Linebery and Evelyn Linebery, Petitioners v. Commissioner of Internal Revenue, Respondent
Linebery v. Commissioner
Docket No. 8090-71
United States Tax Court
64 T.C. 108; 1975 U.S. Tax Ct. LEXIS 158;
April 28, 1975, Filed
Decision will be entered under Rule 155.
Held, petitioners' monthly receipts, measured by a percentage of the amounts received by Shell Oil Co. from the sale of water transported through pipelines laid on right-of-way across petitioners' land, are taxable as ordinary income. Held, further, amounts received by petitioners from the extraction of caliche under terminable…
2Cases cited13 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Anderson v. HelveringSupreme Court of the United States · 1940
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Nathaniel C. Wood and Gertrude L. Wood v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Earl Vest and Fay Vest, Petitioners-Appellees-Cross v. Commissioner of Internal Revenue, Respondent-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
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