Legal Opinion

Oblinger v. Commissioner

United States Tax Court

Decided February 23, 1993No. Docket No. 29163-90Published

Petitioner, a charitable trust owning farmland, entered into three sharecrop leases. The sharecrop leases provided for rent to be determined on a fixed percentage of the crops harvested. The sharecrop leases also provided for the sharing of certain expenses. Held, the amount of rent is not determined, in whole or in part, on the income or profits of the sharecroppers; thus the rents are excluded from UBIT under sec. 512(b) (3) (B) (ii), I.R.C.

1Opinion of the Court

TRUST U/W EMILY OBLINGER, STEPHEN DEXTER AND EMILY JANE TIPTON DOLE a/k/a THE STEPHEN DEXTER DOLE AND EMILY JANE TIPTON DOLE TRUST FUND, BANCENTRAL TRUST, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Oblinger v. Commissioner

Docket No. 29163-90

United States Tax Court

100 T.C. 114; 1993 U.S. Tax Ct. LEXIS 9; 100 T.C. No. 9;

February 23, 1993, Filed

Decision will be entered under Rule 155.

Petitioner, a charitable trust owning farmland, entered into three sharecrop leases. The sharecrop leases provided for rent to be determined on a fixed percentage of the crops harvested. The…

2Cases cited11 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Bauschard v. CommissionerUnited States Tax Court · 1959
  3. Raymond Bauschard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
  4. Haley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  5. State National Bank of El Paso, Trustee for Lee Moor Children's Home v. United StatesCourt of Appeals for the Fifth Circuit · 1975

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