Cooper v. Commissioner
United States Tax Court
1. Held, the petitioners are not entitled to depletion deductions for coal they mined under oral agreements with the lessee of land containing coal. 2. Held, further, the petitioners at Docket No. 70456 failed to show that they are not subject to the penalty for failure to file a declaration of estimated tax for the year 1953.
1Opinion of the Court
Fax, Judge:
The respondent determined deficiencies in the petitioners’ income taxes and additions to tax, as follows:
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The incorrectness of the addition to tax under section 294(d) (2) was conceded by respondent at the trial of these cases.
The only questions for decision are (1) whether the petitioners are entitled to percentage depletion on income derived from mining coal under agreements with the Jewell Nidge Coal Corporation and (2) whether the petitioners at Docket No. 70456 had reasonable cause for failing to file a declaration of estimated tax for the year 1953.
FINDINGS OF…
2Cases cited6 opinions
- Parsons v. SmithSupreme Court of the United States · 1959
- United States v. James C. And Helen M. Stallard, and Dewey H. And Geneva StallardCourt of Appeals for the Fourth Circuit · 1959
- Bolling v. CommissionerUnited States Tax Court · 1962
- McCall v. CommissionerUnited States Tax Court · 1962
- Legg v. CommissionerUnited States Tax Court · 1962
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Lawson v. CommissionerUnited States Tax Court · 1963
- Cooper v. CommissionerUnited States Tax Court · 1962
- Ison v. CommissionerUnited States Tax Court · 1963