Ramsey v. Commissioner
United States Board of Tax Appeals
Petitioner exercised his option under article 225 of Regulations 65 to charge certain development costs to operating expense. Held, that such costs may not be capitalized to determine basis of gain or loss on sale of such property in a later year and after the statute of limitations has run against tax liability in the years in which deductions from income were taken for such expenditures.
1Opinion of the Court
OPINION.
Lansdon :
The respondent has asserted deficiencies in income tax for the years 1925 and 1926 in the respective amounts of $3,041.01 and $51,134.07, but the petitioner’s appeal is only from the determination for 1926.
The petitioner is an individual, residing at Oklahoma City in the State of Oklahoma, where he is engaged in the acquisition, development and exploitation of oil and gas leases. Prior to January 6, 1926, he acquired a group of oil leases in the State of California, which he thereafter developed. and sold to the Ramsey Petroleum Corporation. The first of such leases was…
2Cases cited7 opinions
- United States v. GrimaudSupreme Court of the United States · 1911
- Brewster v. GageSupreme Court of the United States · 1930
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Boske v. ComingoreSupreme Court of the United States · 1900
- Casey v. GalliSupreme Court of the United States · 1877
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3Cited by15 opinions
- Harper Oil Company, a Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1970
- Standard Oil Co. v. Collector of RevenueSupreme Court of Louisiana · 1946
- Shaffer v. CommissionerUnited States Board of Tax Appeals · 1934
- Crossett Timber & Development Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Wheelock v. CommissionerUnited States Board of Tax Appeals · 1933
10 more not listed; retrieve them via the Exa API.