Laguna Royalty Company (Successor by Merger to Lydia Oil Company) v. Commissioner of Internal Revenue

Fifth Circuit

Laguna Royalty Company (Successor by Merger to Lydia Oil Company) v. Commissioner of Internal Revenue

406 F.2d 703

CourtCourt of Appeals for the Fifth Circuit

DecidedMarch 7, 1969

Docket26291

StatusPublished

Cited by3 cases

This text of 406 F.2d 703 (Laguna Royalty Company (Successor by Merger to Lydia Oil Company) v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Laguna Royalty Company (Successor by Merger to Lydia Oil Company) v. Commissioner of Internal Revenue, 406 F.2d 703 (5th Cir. 1969).

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Opinion

PER CURIAM:

The question presented by this appeal is whether the Tax Court correctly decided that, in the case of oil and gas producing properties, “lifting costs,” which constitute a portion of the cost of producing oil and gas, are to be subtracted from gross sales in computing gross income for the purpose of determining whether personal holding company income, as defined in Section 543 of the Internal Revenue Code of 1954, is at least eighty percent of the corporation’s total gross income for the taxable years.

We have carefully considered the unpublished memorandum findings of fact and opinion of the Tax Court and are fully in accord therewith. Based, therefore, on the findings and opinion of the Tax Court, dated February 28, 1968, we affirm the decision of the Tax Court.

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PER CURIAM:

The question presented by this appeal is whether the Tax Court correctly decided that, in the case of oil and gas producing properties, “lifting costs,” which constitute a portion of the cost of producing oil and gas, are to be subtracted from gross sales in computing gross income for the purpose of determining whether personal holding company income, as defined in Section 543 of the Internal Revenue Code of 1954, is at least eighty percent of the corporation’s total gross income for the taxable years.

We have carefully considered the unpublished memorandum findings of fact and opinion of the Tax Court and are fully in accord therewith. Based, therefore, on the findings and opinion of the Tax Court, dated February 28, 1968, we affirm the decision of the Tax Court.

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Bluebook (online)

406 F.2d 703, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laguna-royalty-company-successor-by-merger-to-lydia-oil-company-v-ca5-1969.

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