Legal Opinion

North Am. Oil Consol. v. Commissioner

United States Board of Tax Appeals

Decided May 24, 1928No. Docket Nos. 8714, 16107Published

1. Assessment and collection of taxes for 1917 held not barred by statute of limitations. 2. Deduction claimed for an amount paid the Oil Industry Association disallowed for lack of evidence. 3. Cost of replacing derricks damaged by fire held not deductible as expense. 4. Portion of proceeds of oil paid attorneys for legal services in defending title to property and securing land patents, held to be capital expenditures.

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1. Assessment and collection of taxes for 1917 held not barred by statute of limitations. 2. Deduction claimed for an amount paid the Oil Industry Association disallowed for lack of evidence. 3. Cost of replacing derricks damaged by fire held not deductible as expense. 4. Portion of proceeds of oil paid attorneys for legal services in defending title to property and securing land patents, held to be capital expenditures. Further held that depletion is allowable in each year in amounts equal to the sums paid to the attorneys. 5. Respondent sustained in disallowing deductions claimed on account…

1Opinion of the Court

NORTH AMERICAN OIL CONSOLIDATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

North Am. Oil Consol. v. Commissioner

Docket Nos. 8714, 16107.

United States Board of Tax Appeals

12 B.T.A. 68; 1928 BTA LEXIS 3602;

May 24, 1928, Promulgated

1. Assessment and collection of taxes for 1917 held not barred by statute of limitations.

2. Deduction claimed for an amount paid the Oil Industry Association disallowed for lack of evidence.

3. Cost of replacing derricks damaged by fire held not deductible as expense.

4. Portion of proceeds of oil paid attorneys for legal services in defending title to…

2Cases cited2 opinions

  1. North American Oil Consolidated v. CommissionerUnited States Board of Tax Appeals · 1928
  2. North Am. Oil Consol. v. CommissionerUnited States Board of Tax Appeals · 1928

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