Legal Opinion

Hazlett v. Commissioner

United States Board of Tax Appeals

Decided January 28, 1928No. Docket No. 9441Published

1. The bonus in addition to reserved royalties received by the petitioner in payment for a certain oil lease was not a return of capital.

Read the full summary

1. The bonus in addition to reserved royalties received by the petitioner in payment for a certain oil lease was not a return of capital. Appeal of Nelson Land & Oil Co.,3 B.T.A. 315. 2. The bonus received as set forth above is income and is not taxable under the provisions of section 206 of the Revenue Act of 1921. Henry L. Berg v. Commissioner,6 B.T.A. 1287. 3. The evidence does not sustain discovery value of the lease here involved in addition to such value already determined by the respondent.

1Opinion of the Court

R. H. HAZLETT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hazlett v. Commissioner

Docket No. 9441.

United States Board of Tax Appeals

10 B.T.A. 332; 1928 BTA LEXIS 4123;

January 28, 1928, Promulgated

1. The bonus in addition to reserved royalties received by the petitioner in payment for a certain oil lease was not a return of capital. Appeal of Nelson Land & Oil Co.,3 B.T.A. 315.

2. The bonus received as set forth above is income and is not taxable under the provisions of section 206 of the Revenue Act of 1921. Henry L. Berg v. Commissioner,6 B.T.A. 1287.

3. The evidence does not…

2Cases cited3 opinions

  1. Berg v. CommissionerUnited States Board of Tax Appeals · 1927
  2. Nelson Land & Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  3. Hazlett v. CommissionerUnited States Board of Tax Appeals · 1928

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API