Legal Opinion

James Maddrix and Alice Maddrix v. Commissioner of Internal Revenue

Court of Appeals for the Eleventh Circuit

Decided January 22, 1986No. 85-3173PublishedCited by 19 opinions

1Opinion of the Court

ANDERSON, Circuit Judge:

James Maddrix and Alice Maddrix (“Taxpayer”) 1 appeal from a decision of the Tax Court disallowing, inter alia, certain advanced minimum royalty deductions and determining a $74,069.51 deficiency in their 1977 joint federal income tax return. This case presents a question of first impression concerning the proper application of 26 C.F.R. § 1.612-3(b)(3) (1985), which governs the deductibility of advanced minimum royalties paid or accrued in connection with mineral deposits. We affirm.

I. BACKGROUND

Taxpayer is the owner of an undivided working interest in a mineral…

2Cases cited6 opinions

  1. Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
  2. Wing v. CommissionerUnited States Tax Court · 1983
  3. Paul P. Brountas v. Commissioner of Internal Revenue, Paul P. And Lynn T. Brountas v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1982
  4. Gibson Products Co. Kell Blvd. v. United StatesCourt of Appeals for the Fifth Circuit · 1981
  5. Crc Corporation v. Commissioner of Internal Revenue. Crc Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1982

1 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Ferrell v. CommissionerUnited States Tax Court · 1988
  2. Jimmie J. And Bonnie M. Ward v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986
  3. Jack Brown and Clara Brown v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
  4. Long v. United StatesUnited States Court of Claims · 1986
  5. T. Ree McCoy Nancy McCoy v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1986

14 more not listed; retrieve them via the Exa API.

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