Koziara v. Commissioner
United States Tax Court
Petitioners owned land in Michigan under which oil and gas deposits were located. Oil and gas deposits also were located under land adjacent to petitioners' land. The deposits were part of a single, larger reservoir of oil and gas.
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Petitioners owned land in Michigan under which oil and gas deposits were located. Oil and gas deposits also were located under land adjacent to petitioners' land. The deposits were part of a single, larger reservoir of oil and gas. In 1973, the Michigan Supervisor of Wells issued an order under Michigan law (referred to as a unitization order) restricting petitioners and the other owners of land overlaying the oil and gas reservoir from independently extracting oil and gas from the reservoir. Under the unitization order, only Sun Oil Co. was allowed to extract oil and gas from the reservoir,…
1Opinion of the Court
'■OPINION
SWIFT, Judge:
This matter is before the Court on cross motions for súmmary judgment, filed October 19, 1984. These cases have been consolidated for purposes of trial, briefing, and opinion. The pertinent facts have been fully-stipulated and are set forth below.
In separate statutory notices of deficiency dated April 7, 1980, respondent determined deficiencies in petitioners’ Federal income tax liabilities and additions to tax as follows:
Petitioners Eugene H. Koziara and Laura A. Koziara
Docket No. 10828-80
Additions to tax
Year Deficiencies sec. 49731
1975 $244.29 $73.38
1976 7,144.93 73.38
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2Cases cited8 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Kittle v. CommissionerUnited States Tax Court · 1953
- Wronski v. Sun Oil CompanyMichigan Court of Appeals · 1979
- Otis A. Kittle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Estate of Reinke v. CommissionerUnited States Tax Court · 1993
- Lakewood Assocs. v. CommissionerUnited States Tax Court · 1997
- Koziara v. CommissionerUnited States Tax Court · 1986
- Lakewood Associates, Robert G. Moore, Tax Matters Partner v. CommissionerUnited States Tax Court · 1997
- Lakewood Assocs. v. CommissionerUnited States Tax Court · 1997
1 more not listed; retrieve them via the Exa API.