Glass v. Commissioner
United States Tax Court
In 1975, petitioners received bonuses in the total amount of $ 139,940 upon the execution of several oil and gas leases. Producing oil or gas wells were completed during 1975 on all except one of the properties covered by the leases. The bonus received with respect to the lease on which no well was completed was $ 19,200. In addition to the bonuses, petitioners received royalties of $ 24,811 from the producing leases.
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In 1975, petitioners received bonuses in the total amount of $ 139,940 upon the execution of several oil and gas leases. Producing oil or gas wells were completed during 1975 on all except one of the properties covered by the leases. The bonus received with respect to the lease on which no well was completed was $ 19,200. In addition to the bonuses, petitioners received royalties of $ 24,811 from the producing leases. Held, petitioners are not entitled to percentage depletion under sec. 613A(c), I.R.C. 1954, with respect to the lease bonuses.
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined a deficiency in the amount of $15,472.20 in petitioners’ Federal income tax for 1975. The only issue for decision is whether petitioners are entitled to deduct percentage depletion under sections 6111 and 613A with respect to certain oil and gas lease bonus payments which they received in 1975.
All of the facts have been stipulated.
Petitioners, who are husband and wife, filed a joint Federal income tax return for 1975 with the Internal Revenue Service Center, Austin, Tex. At the time the petition herein was filed, they were legal residents of…
2Cases cited14 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Burnet v. HarmelSupreme Court of the United States · 1932
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- Garcia v. KingTexas Supreme Court · 1942
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