Legal Opinion

Big Four Oil & Gas Co. v. Commissioner

United States Board of Tax Appeals

Decided May 11, 1933No. Docket No. 54478Published

For many years petitioner was allowed depletion deductions upon the basis of the March 1, 1913, estimate of recoverable oil reserves. During 1928 it was discovered that the original estimate was too low. Respondent made a new estimate as of January 1, 1928, upon which he computed depletion deductions. Held, respondent had authority to reestimate the amount of reserves and to compute allowable depletion deductions upon the new basis.

1Opinion of the Court

BIG FOUR OIL & GAS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Big Four Oil & Gas Co. v. Commissioner

Docket No. 54478.

United States Board of Tax Appeals

28 B.T.A. 61; 1933 BTA LEXIS 1186;

May 11, 1933, Promulgated

For many years petitioner was allowed depletion deductions upon the basis of the March 1, 1913, estimate of recoverable oil reserves. During 1928 it was discovered that the original estimate was too low. Respondent made a new estimate as of January 1, 1928, upon which he computed depletion deductions. Held, respondent had authority to reestimate the amount of…

2Cases cited1 opinion

  1. Big Four Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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