Strutzel v. Commissioner
United States Tax Court
Petitioners transferred their interests in unpatented mining claims under a document entitled "Mining Lease and Option to Purchase."
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Petitioners transferred their interests in unpatented mining claims under a document entitled "Mining Lease and Option to Purchase." The transfer was for a term of approximately 10 years and the transferee was given the option to purchase at any time during the term of the lease for $ 500,000. Petitioners were to receive fixed annual payments in increasing amounts, and production royalties to be offset against the fixed annual payments, with both to be applied against the purchase price if the option was exercised. The fixed annual payments totaled $ 500,000 if paid throughout the term of the…
1Opinion of the Court
Joseph J. Strutzel, Jr., and Justine W. Strutzel, Petitioners v. Commissioner of Internal Revenue, Respondent; Mark T. and Louise D. Miller, Petitioners v. Commissioner of Internal Revenue, Respondent
Strutzel v. Commissioner
Docket Nos. 6449-69, 6450-69
United States Tax Court
60 T.C. 969; 1973 U.S. Tax Ct. LEXIS 49; 60 T.C. No. 103;
September 25, 1973, Filed
Decision will be entered under Rule 50 in docket No. 6450-69.
Decision will be entered for the petitioners in docket No. 6449-69.
Petitioners transferred their interests in unpatented mining claims under a document entitled "Mining Lease and…
2Cases cited1 opinion
- Strutzel v. CommissionerUnited States Tax Court · 1973