Cline v. Commissioner
United States Tax Court
In consideration for the negotiation of certain coal leases on behalf of the operator, petitioners acquired royalty interests in those leases. Subsequently, petitioners and the operator entered into a second contract whereby, in lieu of a royalty on coal mined from the specific leases, petitioners would receive a lesser royalty on all the coal handled by the operator.
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In consideration for the negotiation of certain coal leases on behalf of the operator, petitioners acquired royalty interests in those leases. Subsequently, petitioners and the operator entered into a second contract whereby, in lieu of a royalty on coal mined from the specific leases, petitioners would receive a lesser royalty on all the coal handled by the operator. Held, the second contract resulted in the sale or exchange of the royalty interests acquired by petitioners under the original contract; under the second contract, the petitioners did not retain an economic interest within the…
1Opinion of the Court
Herbert B. Cline, Jr., and Brisy Cline, Petitioners v. Commissioner of Internal Revenue, Respondent; John C. Cline and Mildred Cline, Petitioners v. Commissioner of Internal Revenue, Respondent
Cline v. Commissioner
Docket Nos. 3517-75, 3518-75
United States Tax Court
67 T.C. 889; 1977 U.S. Tax Ct. LEXIS 142;
March 7, 1977, Filed
Decisions will be entered under Rule 155.
In consideration for the negotiation of certain coal leases on behalf of the operator, petitioners acquired royalty interests in those leases. Subsequently, petitioners and the operator entered into a second contract whereby, in…
Also in this document: Dissent.
2Cases cited18 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Paragon Jewel Coal Co. v. CommissionerSupreme Court of the United States · 1965
- United States v. William D. Frazell and Martha T. FrazellCourt of Appeals for the Fifth Circuit · 1964
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