John Province 1 Well v. Commissioner
United States Tax Court
Petitioners are several gas wells drilled on leaseholds obtained by J. O. Boyle, who made assignments of fractional interests in the wells in return for funds supplied to him by the assignees. Boyle retained all managerial rights, including the sole authority to sell the gas produced. Boyle also retained fractional interests in the respective wells. Held, petitioners are associations taxable as corporations.
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Petitioners are several gas wells drilled on leaseholds obtained by J. O. Boyle, who made assignments of fractional interests in the wells in return for funds supplied to him by the assignees. Boyle retained all managerial rights, including the sole authority to sell the gas produced. Boyle also retained fractional interests in the respective wells. Held, petitioners are associations taxable as corporations. Held, further, the incomes of petitioners include the entire receipts derived from sales of gas from the wells.
1Opinion of the Court
John Provence #1 Well, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
John Province #1 Well v. Commissioner
Docket Nos. 78153-78160, 78163, 78164
United States Tax Court
37 T.C. 376; 1961 U.S. Tax Ct. LEXIS 24; 15 Oil & Gas Rep. 684;
November 29, 1961, Filed November 29, 1961, Filed
Decisions will be entered under Rule 50.
Petitioners are several gas wells drilled on leaseholds obtained by J. O. Boyle, who made assignments of fractional interests in the wells in return for funds supplied to him by the assignees. Boyle retained all managerial rights, including the sole…
2Cases cited22 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Hecht v. MalleySupreme Court of the United States · 1924
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Smith v. CommissionerUnited States Tax Court · 1959
- Commissioner of Internal Rev. v. Horseshoe L. SyndicateCourt of Appeals for the Fifth Circuit · 1940
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