Simms Petroleum Co. v. Commissioner
United States Board of Tax Appeals
1. Losses allowable on account of the abandonment or other disposition of oil leases determined. 2. A net loss sustained by a member of an affiliated group in 1923 may not be carried forward under the provisions of section 206 of the Revenue Act of 1926 and allowed as a deduction in computing consolidated net income in 1925 where the corporation which sustained the net loss in 1923 had no net income in 1925. 3. A liquidation in kind held not to have occurred through an…
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1. Losses allowable on account of the abandonment or other disposition of oil leases determined. 2. A net loss sustained by a member of an affiliated group in 1923 may not be carried forward under the provisions of section 206 of the Revenue Act of 1926 and allowed as a deduction in computing consolidated net income in 1925 where the corporation which sustained the net loss in 1923 had no net income in 1925. 3. A liquidation in kind held not to have occurred through an agreement between a majority of the stockholders of a corporation and a purchaser of such stock wherein it ws agreed that any…
1Opinion of the Court
*1118OPINION.
Issue No. 1.
Seawell :
The first issue involved is entirely one of fact, namely, the amount of losses to which the Simms Oil Co. is entitled on account of the abandonment or other disposition of certain oil leases in 1922,1923, 1924, and 1925. The parties have stipulated that the Commissioner did not allow any cost basis on account of the acquisition of the leases in question on June 20, 1919, and accordingly *1119included in taxable income tbe entire proceeds, if any, arising from their disposition. We have found as a fact that the cost of the leases to the Simms Oil Co. was $972,012.94 and…
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- United States v. Dakota-Montana Oil Co.Supreme Court of the United States · 1933
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Burnet v. A. T. Jergins TrustSupreme Court of the United States · 1933
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3Cited by2 opinions
- Simms Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Wilmington Trust Co. v. LatchumDistrict Court, D. Delaware · 1942