Buckley v. Commissioner
United States Tax Court
1. Petitioners held certificates of ownership 1The terms "certificates of ownership," "units of ownership," "shares," and "stock" are used interchangeably hereinafter, as are the terms "certificate holders," "unit holders," "shareholders," and "stockholders." in two organizations formed under the laws of Venezuela as "anonymous companies" which held royalty rights to certain oil producing realty in Venezuela.
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1. Petitioners held certificates of ownership 1The terms "certificates of ownership," "units of ownership," "shares," and "stock" are used interchangeably hereinafter, as are the terms "certificate holders," "unit holders," "shareholders," and "stockholders." in two organizations formed under the laws of Venezuela as "anonymous companies" which held royalty rights to certain oil producing realty in Venezuela. Those companies had broad powers to carry on business, held title to property in their own right, had centralized management and continuity of enterprise uninterrupted by deaths among…
1Opinion of the Court
William F. Buckley and Aloise S. Buckley, Petitioners, v. Commissioner of Internal Revenue, Respondent
Buckley v. Commissioner
Docket Nos. 32308, 44108
United States Tax Court
22 T.C. 1312; 1954 U.S. Tax Ct. LEXIS 82; 3 Oil & Gas Rep. 2119;
September 30, 1954, Filed September 30, 1954, Filed
Decisions will be entered under Rule 50.
1. Petitioners held certificates of ownership 1 in two organizations formed under the laws of Venezuela as "anonymous companies" which held royalty rights to certain oil producing realty in Venezuela. Those companies had broad powers to carry on business, held title to…
2Cases cited1 opinion
- Buckley v. CommissionerUnited States Tax Court · 1954