James Petroleum Corporation v. Commissioner of Internal Revenue

CLARK, Chief Judge.

This petition for review of a decision of the Tax Court, 24 T.C. 509, assessing deficiencies against the petitioner-taxpayer in its income taxes for 1947 and 1948 raises issues as to the disallowance of its claimed deductions for losses of oil royalty interests and for depletion of such interests. On the first point petitioner contests the conclusion of the Tax Court that oil royalties which it sold for a nominal amount had become worthless prior to the year of sale and consequently did not give rise to deductible losses in that year under § 23(f) of the Internal Revenue…