Patin v. Commissioner
United States Tax Court
Ps, individual investors, each purchased from O specified tonnages of ore in the form of one or more undesignated ore blocks for a price of $ 50 plus a 50-percent overriding royalty. Under the purchase agreements, ore blocks were to be randomly assigned to Ps by O at an unspecified later date and from an unspecified mining property or properties.
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Ps, individual investors, each purchased from O specified tonnages of ore in the form of one or more undesignated ore blocks for a price of $ 50 plus a 50-percent overriding royalty. Under the purchase agreements, ore blocks were to be randomly assigned to Ps by O at an unspecified later date and from an unspecified mining property or properties. Ps then contracted with A, an affiliate of O, to perform mining development services with respect to such ore for a fee of $ 50 per ton. The development fee was paid one-sixth with cash and five-sixths with funds allegedly borrowed from K, evidenced…
1Opinion of the Court
FEATHERSTON, Judge:
These consolidated cases were assigned to Special Trial Judge Marvin F. Peterson pursuant to section 7456(d)2 (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755), and Rules 180, 181, and 183.3 The Court agrees with and adopts his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PETERSON, Special Trial Judge: These consolidated cases were selected by counsel and approved by the Court to serve as test cases for resolving issues common to a much larger group of petitioners who invested during 1980 in the…
2Cases cited27 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Bixby v. CommissionerUnited States Tax Court · 1972
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
22 more not listed; retrieve them via the Exa API.
3Cited by189 opinions
- Rybak v. CommissionerUnited States Tax Court · 1988
- William S. Skeen and Alison Skeen v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- Cherin v. CommissionerUnited States Tax Court · 1987
- McCrary v. CommissionerUnited States Tax Court · 1989
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
184 more not listed; retrieve them via the Exa API.