Legal Opinion

Peabody Natural Resources Company, f.k.a. Hanson Natural Resources Company, Cavenham Forest Industries, Inc., A Partner Other Than The Tax Matters Partner v. Commissioner

United States Tax Court

Decided May 8, 2006No. 20328-04, 6899-05Unknown

1Opinion of the Court

126 T.C. No. 14

UNITED STATES TAX COURT PEABODY NATURAL RESOURCES COMPANY, f.k.a. HANSON NATURAL RESOURCES COMPANY, CAVENHAM FOREST INDUSTRIES, INC., A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 20328-04, 6899-05. Filed May 8, 2006. A partnership exchanged operating gold mines, including realty, for operating coal mines. The coal mines were subject to two coal supply contracts that obligated the mine owner to provide electric utilities with coal. The benefits and obligations under the contracts were governed by New Mexico…

2Cases cited25 opinions

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
  5. Craig v. Comm'rUnited States Tax Court · 2002

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