Signal Gasoline Corp. v. Commissioner
United States Board of Tax Appeals
The petitioner is the owner of certain contracts under which it purchases casinghead gas from the owners of producing oil and gas properties. Through its own pipe lines it transports such gas to its own plant for conversion into commercial gasoline.
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The petitioner is the owner of certain contracts under which it purchases casinghead gas from the owners of producing oil and gas properties. Through its own pipe lines it transports such gas to its own plant for conversion into commercial gasoline. Subject to certain limitations, it is entitled to depletion allowances from its income in each of the taxable years to the extent of 27 1/2 percent of the gross income realized in its production of casinghead gas under its contracts. Held, that in computing such allowances under the provisions of section 204(c)(2) of the Revenue Act of 1926, the…
1Opinion of the Court
OPINION.
Lansdon:
The respondent determined deficiencies in income tax for the years 1924,1925, and 1926. In its appeal from such determinations the petitioner contended that' its allowances for depletion in the taxable years had been erroneously reduced in the respective amounts of $45,816.06, $124,445.17, and $257,187.32. In Signal Gasoline Corp., 25 B.T.A. 861, we held as to the principal issue that owners of casinghead gas contracts have no depletable interest in the oil and gas properties from which the wet gas is recovered and affirmed the determinations of the respondent. In due course…
2Cases cited6 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Burnet v. ClarkSupreme Court of the United States · 1932
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Brea Canon Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Shamrock Oil & Gas Corp. v. CommissionerUnited States Tax Court · 1961
- Hugoton Production Company v. The United StatesUnited States Court of Claims · 1963
- Consumers Natural Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Bankline Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1937
- Lomita Gasoline Co. v. CommissionerUnited States Board of Tax Appeals · 1935
4 more not listed; retrieve them via the Exa API.