Legal Opinion

Cook Drilling Co. v. Commissioner

United States Board of Tax Appeals

Decided August 9, 1938No. Docket No. 82231Published

1. OIL PAYMENT CONTRACTS. - Held, that the fair market value of contracts for future payments out of oil if, as, and when produced, in consideration for drilling certain oil wells and for the sale of oil and gas leases, is not includable in gross income; held, further, that oil payments actually collected on such contracts during the taxable year constituted gross income. 2. Id. - Held, that drilling costs incurred in drilling wells completed during the taxable year are…

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1. OIL PAYMENT CONTRACTS. - Held, that the fair market value of contracts for future payments out of oil if, as, and when produced, in consideration for drilling certain oil wells and for the sale of oil and gas leases, is not includable in gross income; held, further, that oil payments actually collected on such contracts during the taxable year constituted gross income. 2. Id. - Held, that drilling costs incurred in drilling wells completed during the taxable year are deductible as business expenses. Edwards Drilling Co.,35 B.T.A. 341; affd., 95 Fed.(2d) 719, followed. 3. Id. - Held, that…

1Opinion of the Court

COOK DRILLING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Cook Drilling Co. v. Commissioner

Docket No. 82231.

United States Board of Tax Appeals

38 B.T.A. 291; 1938 BTA LEXIS 888;

August 9, 1938, Promulgated

1. OIL PAYMENT CONTRACTS. - Held, that the fair market value of contracts for future payments out of oil if, as, and when produced, in consideration for drilling certain oil wells and for the sale of oil and gas leases, is not includable in gross income; held, further, that oil payments actually collected on such contracts during the taxable year constituted gross…

2Cases cited4 opinions

  1. Thomas v. PerkinsSupreme Court of the United States · 1937
  2. Edwards Drilling Co. v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Dearing v. CommissionerUnited States Board of Tax Appeals · 1937
  4. Cook Drilling Co. v. CommissionerUnited States Board of Tax Appeals · 1938

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