Monroe Coal Mining Co. v. Commissioner
United States Tax Court
1. A coal mining company, having elected the percentage method of computing its depletion allowance, in 1940 received income from the sale proceeds of discarded mine equipment and discounts because of prompt payment for new equipment purchased.
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1. A coal mining company, having elected the percentage method of computing its depletion allowance, in 1940 received income from the sale proceeds of discarded mine equipment and discounts because of prompt payment for new equipment purchased. Such amounts, held, not to be "gross income from the property" within the meaning of section 114 (b) (4) (B), Internal Revenue Code, as amended by section 124 (c), Revenue Act of 1943. 2. A coal mining company, having elected the percentage method of computing its depletion allowance, sustained an operating loss in 1939 and hence was entitled to no…
1Opinion of the Court
OPINION.
Johnson, Judge-.
The Commissioner determined a deficiency of $7,503.16 in petitioner’s income tax for 1940, in part by the disallowance of a claimed net operating loss deduction of $45,605.65 carried over from 1939 and by eliminating from the gross income of petitioner’s coal mining property $7,128.02 received from the sales of scrapped equipment and $468.08 representing discounts allowed because of prompt payment for operating equipment purchased. These eliminations reduced the income from the property, and consequently the amount deductible as percentage depletion. The case was…
2Cases cited3 opinions
- F. H. E. Oil Co. v. CommissionerUnited States Tax Court · 1944
- Montreal Mining Co. v. CommissionerUnited States Tax Court · 1943
- Virgilia Mining Corp. v. CommissionerUnited States Tax Court · 1946
3Cited by7 opinions
- Island Creek Coal Co. v. CommissionerUnited States Tax Court · 1958
- General Portland Cement Co., Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1980
- Elk Lick Coal Co. v. CommissionerUnited States Tax Court · 1954
- Cranberry Improvement Co. v. SmithDistrict Court, E.D. Pennsylvania · 1954
- Elk Lick Coal Co. v. CommissionerUnited States Tax Court · 1954
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