Legal Opinion

Horton v. Commissioner

United States Tax Court

Decided October 14, 1946No. Docket Nos. 4206, 8534Published

Petitioner and Lee, the owner of a mining concession in Mexico, entered into an agreement whereby the latter assigned to petitioner the privilege of developing the property for a period of nine years, and petitioner agreed to supply the funds necessary to put the property in a "good and proper state of exploitation."

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Petitioner and Lee, the owner of a mining concession in Mexico, entered into an agreement whereby the latter assigned to petitioner the privilege of developing the property for a period of nine years, and petitioner agreed to supply the funds necessary to put the property in a "good and proper state of exploitation." It was also agreed that the total value of the net products of the mine should be divided as follows: 100 per cent to petitioner until he was reimbursed for expenditures made in preparing property for exploitation; thereafter 60 per cent to Lee and 40 per cent to petitioner until…

1Opinion of the Court

Hiram T. Horton, Petitioner, v. Commissioner of Internal Revenue, Respondent

Horton v. Commissioner

Docket Nos. 4206, 8534

United States Tax Court

7 T.C. 957; 1946 U.S. Tax Ct. LEXIS 60;

October 14, 1946, Promulgated

Decision will be entered under Rule 50.

Petitioner and Lee, the owner of a mining concession in Mexico, entered into an agreement whereby the latter assigned to petitioner the privilege of developing the property for a period of nine years, and petitioner agreed to supply the funds necessary to put the property in a "good and proper state of exploitation." It was also agreed that the…

2Cases cited1 opinion

  1. Horton v. CommissionerUnited States Tax Court · 1946

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