Rife v. Commissioner
United States Tax Court
Held: 1. Charges made to the drawing account of petitioner M. O. Rife, Jr., in 1955, 1956, and 1957 on the books of a partnership of which he was a partner for amounts billed to him by the partnership for drilling done for him by the partnership did not constitute payment of the amounts by petitioner until the close of the partnership's fiscal years on March 31, 1956, 1957, and 1958. Since petitioner kept his books and reported his income on the cash basis, the amounts of…
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Held: 1. Charges made to the drawing account of petitioner M. O. Rife, Jr., in 1955, 1956, and 1957 on the books of a partnership of which he was a partner for amounts billed to him by the partnership for drilling done for him by the partnership did not constitute payment of the amounts by petitioner until the close of the partnership's fiscal years on March 31, 1956, 1957, and 1958. Since petitioner kept his books and reported his income on the cash basis, the amounts of such charges were deductible by him when paid by him at the close of the partnership's fiscal years and not prior thereto.…
1Opinion of the Court
OPINION
Issue 1
The first issue is whether petitioners are entitled to deduct intangible drilling and development expenses as of the time such expenses were incurred and charged to petitioner’s drawing account with Drilling, a partnership in which petitioner was a principal partner, or in a subsequent year when the accounts of the partnership were closed. Petitioner's take the position that these expenses are deductible as of the time they were charged to petitioner’s drawing accomit by the partnership. It is respondent’s position that petitioner, who keeps his books and reports his income on…
2Cases cited12 opinions
- Hulburd v. CommissionerSupreme Court of the United States · 1935
- Flynn v. CommissionerUnited States Tax Court · 1963
- McAdams v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
- Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
- Howard M. Reineman and Helen Reineman v. United StatesCourt of Appeals for the Seventh Circuit · 1962
7 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Saviano v. CommissionerUnited States Tax Court · 1983
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Collins v. CommissionerUnited States Tax Court · 1974
- Parsons v. CommissionerUnited States Tax Court · 1964
- United States Holding Co. v. CommissionerUnited States Tax Court · 1965
25 more not listed; retrieve them via the Exa API.