Missouri River Sand Co. v. Commissioner
United States Tax Court
Petitioner engaged in sand and gravel dredging at two locations on the Missouri River pursuant to nonexclusive licenses which granted no interest in the minerals in place. Held, petitioner did not have an economic interest in said deposits sufficient to entitle it to percentage depletion deductions.
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Petitioner engaged in sand and gravel dredging at two locations on the Missouri River pursuant to nonexclusive licenses which granted no interest in the minerals in place. Held, petitioner did not have an economic interest in said deposits sufficient to entitle it to percentage depletion deductions. Commissioner v. Southwest Exploration Co., 350 U.S. 308 (1956); Oil City Sand & Gravel Co. v. Commissioner, 32 T.C. 31 (1959); and Victory Sand & Concrete, Inc. v. Commissioner, 61 T.C. 407 (1947), distinguished.
1Opinion of the Court
Missouri River Sand Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Missouri River Sand Co. v. Commissioner
Docket No. 15685-80
United States Tax Court
83 T.C. 193; 1984 U.S. Tax Ct. LEXIS 43; 83 T.C. No. 12;
August 7, 1984; As Amended August 7, 1984 August 7, 1984, Filed
Decision will be entered for the respondent.
Petitioner engaged in sand and gravel dredging at two locations on the Missouri River pursuant to nonexclusive licenses which granted no interest in the minerals in place. Held, petitioner did not have an economic interest in said deposits sufficient to entitle it to…
2Cases cited10 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Parsons v. SmithSupreme Court of the United States · 1959
- Weaver v. CommissionerUnited States Tax Court · 1979
- Ramey v. CommissionerUnited States Tax Court · 1967
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