Legal Opinion

Irom v. Commissioner

United States Tax Court

Decided May 12, 1988No. Docket No. 39238-86Unpublished

P, a sublessee in coal mining property, agreed to pay S (sublessor) a minimum annual royalty, payable out of the proceeds of coal production. The royalties for the first two years of the sublease were payable part in cash and part by recourse promissory notes. Royalties for the remaining years of the sublease were payable by nonrecourse promissory notes.

Read the full summary

P, a sublessee in coal mining property, agreed to pay S (sublessor) a minimum annual royalty, payable out of the proceeds of coal production. The royalties for the first two years of the sublease were payable part in cash and part by recourse promissory notes. Royalties for the remaining years of the sublease were payable by nonrecourse promissory notes. All promissory notes were due December 31, 1998. Upon default in payment of any royalties, S could, at his option, declare all notes due and payable, or terminate the sublease. On his 1980 Federal income tax return, P claimed a loss in the…

1Opinion of the Court

JOSEPH M. IROM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Irom v. Commissioner

Docket No. 39238-86.

United States Tax Court

T.C. Memo 1988-211; 1988 Tax Ct. Memo LEXIS 239; 55 T.C.M. (CCH) 842; T.C.M. (RIA) 88211;

May 12, 1988; As amended May 17, 1988; Vacated and Remanded January 20, 1989

P, a sublessee in coal mining property, agreed to pay S (sublessor) a minimum annual royalty, payable out of the proceeds of coal production. The royalties for the first two years of the sublease were payable part in cash and part by recourse promissory notes. Royalties for the remaining years of…

2Cases cited8 opinions

  1. Jacklin v. CommissionerUnited States Tax Court · 1982
  2. Todd v. CommissionerUnited States Tax Court · 1987
  3. Wing v. CommissionerUnited States Tax Court · 1983
  4. Vastola v. CommissionerUnited States Tax Court · 1985
  5. Maddrix v. CommissionerUnited States Tax Court · 1984

3 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API