St. Marys Oil & Gas Co. v. Commissioner
United States Board of Tax Appeals
Interest paid on money borrowed on the general credit of petitioner, and used to purchase part of the property from which oil and gas was produced, must be deducted from gross income in arriving at the net income from the property for the purpose of computing percentage depletion.
1Opinion of the Court
*271OPINION.
ÁRUNDeií :
In the memorandum opinion heretofore entered we held that the interest paid in 1935 was “attributable to the mineral property” within the meaning of article 23 (m)-l (A) of Regulations 86, and, therefore was to be deducted in determining the net income from the property under section 114 (b) (3) of the Revenue Act of 1934.
The petitioner contends that for purposes of computing the allowable depletion interest paid should not be deducted from gross income from the property. The effect of this, if sustained, will be to allow a greater depletion deduction than allowed by the…
2Cases cited5 opinions
- Weiss v. WeinerSupreme Court of the United States · 1929
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
- F. H. E. Oil Co. v. HelveringSupreme Court of the United States · 1939
3Cited by8 opinions
- Guanacevi Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
- Sheridan-Wyoming Coal Co. v. HelveringCourt of Appeals for the D.C. Circuit · 1941
- Island Creek Coal Co. v. CommissionerUnited States Tax Court · 1964
- Grison Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1940
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