Ah Pah Redwood Co. v. Commissioner
United States Tax Court
1. Held, the amounts received by petitioner in 1948 and 1949 from Coast Redwood Co. for timber cut by the latter in those years from the property of petitioner are properly taxable as ordinary income. 2. Where petitioner did not in fact ascertain at any time during 1948 and 1949 a discrepancy between its actual timber resources and prior estimates, even though such fact was at all times readily ascertainable, a revision of petitioner's depletion allowance effective for the…
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1. Held, the amounts received by petitioner in 1948 and 1949 from Coast Redwood Co. for timber cut by the latter in those years from the property of petitioner are properly taxable as ordinary income. 2. Where petitioner did not in fact ascertain at any time during 1948 and 1949 a discrepancy between its actual timber resources and prior estimates, even though such fact was at all times readily ascertainable, a revision of petitioner's depletion allowance effective for the years 1948 and 1949 is not warranted under section 23 (m), I. R. C. 1939.
1Opinion of the Court
Ah Pah Redwood Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Ah Pah Redwood Co. v. Commissioner
Docket No. 50695
United States Tax Court
26 T.C. 1197; 1956 U.S. Tax Ct. LEXIS 71;
September 28, 1956, Filed
Decision will be entered for the respondent.
1. Held, the amounts received by petitioner in 1948 and 1949 from Coast Redwood Co. for timber cut by the latter in those years from the property of petitioner are properly taxable as ordinary income.
2. Where petitioner did not in fact ascertain at any time during 1948 and 1949 a discrepancy between its actual timber resources and…
Also in this document: Dissent.
2Cases cited7 opinions
- Beck v. CommissionerUnited States Tax Court · 1950
- Ah Pah Redwood Co. v. CommissionerUnited States Tax Court · 1956
- Carlen v. CommissionerUnited States Tax Court · 1953
- Forbes v. City of Los AngelesCalifornia Court of Appeal · 1929
- McGinn v. WilleyCalifornia Court of Appeal · 1914
2 more not listed; retrieve them via the Exa API.