Legal Opinion

Monrovia Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided June 9, 1933No. Docket Nos. 37912, 45200Published

1. ASSOCIATION. - Where the owners of an oil lease create a trust for the purpose of engaging in business for profit by prospecting and drilling for oil and the marketing thereof, and the trust issues common participating oil agreements to the owners of the lease in payment for their transfer of the lease and subsequently sells to some 200 persons 1,200 shares of preferred participating oil agreements at $100 per share, and engages in business during the taxable years under…

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1. ASSOCIATION. - Where the owners of an oil lease create a trust for the purpose of engaging in business for profit by prospecting and drilling for oil and the marketing thereof, and the trust issues common participating oil agreements to the owners of the lease in payment for their transfer of the lease and subsequently sells to some 200 persons 1,200 shares of preferred participating oil agreements at $100 per share, and engages in business during the taxable years under quasi-corporate form, such trust is an association taxable as a corporation. 2. INCOME OF THE ASSOCIATION. - The…

1Opinion of the Court

MONROVIA OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Monrovia Oil Co. v. Commissioner

Docket Nos. 37912, 45200.

United States Board of Tax Appeals

28 B.T.A. 335; 1933 BTA LEXIS 1140;

June 9, 1933, promulgated

1. ASSOCIATION. - Where the owners of an oil lease create a trust for the purpose of engaging in business for profit by prospecting and drilling for oil and the marketing thereof, and the trust issues common participating oil agreements to the owners of the lease in payment for their transfer of the lease and subsequently sells to some 200 persons 1,200 shares of…

2Cases cited2 opinions

  1. Monrovia Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  2. Graham-Loftus Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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