Legal Opinion
Davis v. Commissioner
Court of Appeals for the Sixth Circuit
Decided October 24, 1984No. Nos. 81-1126, 81-1127 and 81-1187PublishedCited by 19 opinions
1Opinion of the Court
WEICK, Senior Circuit Judge.
These consolidated appeals by the taxpayers and the Commissioner of Internal Revenue are from decisions of the United States Tax Court, rendered by a sharply divided court.
There are two issues involved. The principal issue is whether section 631(c) of the Internal Revenue Code (Code), 26 U.S.C. § 631(c), which permits a sublessor of coal mining rights to treat the royalties he receives from a sublessee of those rights as capital gains, also permits him, as a taxpayer, to deduct from his ordinary income the royalties paid to the lessor for the coal mining rights in…
2Cases cited13 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Commissioner v. EngleSupreme Court of the United States · 1984
8 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Title Insurance. Co. v. State Board of EqualizationCalifornia Supreme Court · 1992
- Clyde Brown, Jr. v. United StatesCourt of Appeals for the Sixth Circuit · 1986
- Deskins v. CommissionerUnited States Tax Court · 1986
- Brown Group v. CommissionerUnited States Tax Court · 1995
- Clyde Brown, Jr. v. United StatesCourt of Appeals for the Sixth Circuit · 1989
14 more not listed; retrieve them via the Exa API.