(DOWNLOAD) "Laster v. Commissioner of Internal Revenue ." by United States Court of Appeals for the Fifth Circuit ~ Book PDF Kindle ePub Free
eBook details
- Title: Laster v. Commissioner of Internal Revenue .
- Author : United States Court of Appeals for the Fifth Circuit
- Release Date : January 17, 1942
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 62 KB
Description
Appealing from an opinion and order of the board, taxpayers present three issues for decision. The first of these, whether taxpayers may deduct as intangible drilling and development costs, amounts paid to drilling contractors in connection with drilling and equipping oil wells, presents as to part of the wells identically, and as to the rest of then, substantially, the same facts, and is to be determined on substantially the same considerations as those in the Retsal case, this day decided in favor of the taxpayer. Though, therefore, the taxpayers are insisting here that the wells on the Taylor and Brown leases were drilled under footage contracts and therefore come even more precisely under the regulations than the others do, it is not necessary in the view we take of the regulation, Cf. Comm. v. Ambrose, 5 Cir., 127 F.2d 47 to determine whether the terms of the Taylor and Brown contracts are really different from the others, since for the reasons set out in the Retsal and Ambrose cases, we decide this issue as to all of the wells, in favor of the taxapyers. The third issue, whether the cost to taxpayers of certain oil payments is recoverable only through depletion, was recently determined in Lee v. Comm., 5 Cir., 126 F.2d 825, in favor of the Commissioner. On the authority of that case, it will be determined here against the taxpayers contention.