Legal Opinion

National Oil Co. v. Commissioner

United States Tax Court

Decided December 23, 1986No. Docket No. 28073-81UnpublishedCited by 1 opinion

Held: Petitioner did not receive capital interests in partnerships in exchange for services during the taxable year; held further, gain on the sale of interests in oil and gas leases is recharacterized as ordinary income.

1Opinion of the Court

NATIONAL OIL COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

National Oil Co. v. Commissioner

Docket No. 28073-81.

United States Tax Court

T.C. Memo 1986-596; 1986 Tax Ct. Memo LEXIS 8; 52 T.C.M. (CCH) 1223; T.C.M. (RIA) 86596;

December 23, 1986.

Held: Petitioner did not receive capital interests in partnerships in exchange for services during the taxable year; held further, gain on the sale of interests in oil and gas leases is recharacterized as ordinary income.

Thomas C. Triplett, for the petitioner.

Mark H. Howard, for the respondent.

WHITAKER

MEMORANDUM FINDINGS OF FACT AND…

2Cases cited8 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Llorente v. CommissionerUnited States Tax Court · 1980
  3. Diamond v. CommissionerUnited States Tax Court · 1971
  4. Sol Diamond and Muriel Diamond v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1974
  5. United States v. W. H. CockeCourt of Appeals for the Fifth Circuit · 1968

3 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. William G. Campbell Norma T. Campbell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991

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