Sterling Coal Co. v. Commissioner
United States Board of Tax Appeals
A taxpayer is not permitted to revise its depletion deduction for previous years as the result of factors determined in subsequent years. If subsequent developments show that a material error has been made in the original estimates of ore reserves a new estimate may be made and the capital remaining to be recovered distributed accordingly.
1Opinion of the Court
*550OPINION.
Trammell:
The respondent contends that the petitioner is entitled to deductions on account of depletion sustained on the Cecil Mine for the fiscal year ended March 31, 1918, of an amount not in excess of $1,783.51 and for the fiscal year ended March 31, 1919, $1,158.36, based upon depletion rate of 3.66837 cents per ton and computed on the valuation of $171,737.24, value as of March 1, 1913, and estimated coal reserve of 4,681,577 tons as of March 1, 1913, and a deduction for the fiscal year ended March 31, 1918, of 51,072 tons and for the fiscal year ended March 31, 1919, of 31,577…
2Cases cited1 opinion
- New Creek Co. v. LedererCourt of Appeals for the Third Circuit · 1924
3Cited by10 opinions
- Big Four Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- McCahill v. CommissionerUnited States Board of Tax Appeals · 1934
- Wylie v. United StatesDistrict Court, N.D. Texas · 1968
- Rust-Owen Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Commissioner of Internal Revenue v. Superior Yarn Mills, Inc.Court of Appeals for the Fourth Circuit · 1955
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