John Provence 1 Well v. Commissioner

HASTIE, Circuit Judge.

In each of these cases, the Tax Court has decided that an agreed business arrangement for the production and marketing of natural gas from a well, in which a number of persons held fractional working interests, was such as to make the enterprise an association taxable as a corporation within the meaning of section 3797(a) (3) of the Internal Revenue Code of 1939, ch. 2, 53 Stat. 469, and the corresponding section 7701(a) (3) of the 1954 Code. 37 T.C. 376. Each case involves the taxable years from 1950 through 1956. The cases have been con*841solidated and for present tax…