Morton Salt Company, a Corporation v. The United States

316 F.2d 931, 161 Ct. Cl. 640, 11 A.F.T.R.2d (RIA) 1466, 1963 U.S. Ct. Cl. LEXIS 15
CourtUnited States Court of Claims
DecidedMay 10, 1963
Docket142-58
StatusPublished
Cited by13 cases

This text of 316 F.2d 931 (Morton Salt Company, a Corporation v. The United States) is published on Counsel Stack Legal Research, covering United States Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morton Salt Company, a Corporation v. The United States, 316 F.2d 931, 161 Ct. Cl. 640, 11 A.F.T.R.2d (RIA) 1466, 1963 U.S. Ct. Cl. LEXIS 15 (cc 1963).

Opinion

JONES, Chief Judge.

Plaintiff, an Illinois corporation having its principal place of business in Chicago, is engaged in the pursuit of extracting, processing, and selling salt in its various forms and grades. As a salt producer, plaintiff is entitled to deduct from its income and excess profits taxes amounts based upon an allowance for the depletion of its mineral resóurces. Plaintiff seeks a refund of its taxes for the years 1951, 1952, 1953, and 1954 on the ground that it was not permitted to base its computations for depletion allowance on its gross income derived from the sale of finished products in those years. Taxpayer’s claim for the first three years in question is predicated upon the provisions of the Internal Revenue Code of 1939 while its 1954 claim is derived from similar provisions of the Internal Revenue Code of 1954.

Section 23 (m) of the Internal Revenue Code of 1939 1 provides for a reason *932 able depletion allowance for the mineral mining industry according to regulations to be prescribed by the Commissioner of Internal Revenue. The basis for this depletion allowance is as set forth in section 114 2 of that Code, and establishes that sodium chloride (salt) is to be depleted at 5 per centum of the gross income from the property during the taxable year. Such “gross income,” the Code explains, means “gross income from mining.” Mining includes “not merely the extraction of the ores or minerals from the ground but also the ordinary treatment processes normally applied by the mine owners or operators in order to obtain the commercially marketable mineral product or products.” These same provisions are carried forward essentially unchanged into the' Internal Revenue Code of 1954, except that the depletion rate for sodium chloride is increased to 10 percent. 3 For simplicity, then, we shall treat all plaintiff’s claims as though they arose under the earlier statutory provisions.

The sole issue 4 presented for decision in this case arises from plaintiff’s contention that all of its processes, including the packaging of its salt, are “normally applied” by miners in order to obtain a commercially marketable product within the meaning of the depletion statute and associated Treasury Regulations. 5

Plaintiff produces salt by hydraulic mining (brine wells) and dry mining (rock salt mines). The salt so produced falls into three basic categories: evaporated granulated salt, evaporated flake or grainer salt, and rock salt. The rock *933 salt is produced by the dry mining method while both of the evaporated forms, basically, are produced by applying a heat evaporation process to the salt received in solution from the brine wells. These mining methods, with minor variations, are identical with those employed by other members of the salt industry. Since there are few secrets within the industry and since the systems are basically simple in principle, standardization is widespread. The process of dry mining, for example, has not been substantially changed in more than 50 years. As the parties have stipulated, and the trial commissioner has found, the treatment processes applied by plaintiff at its plants, with respect to the three basic types of salt, were as follows:

Table 1

Plaintiff takes the position that its production cycle is closed and continuous. As plaintiff’s counsel expresses it, plaintiff

*934 “ * * * starts out with sodium chloride underground, it moves its sodium chloride through a closed production circuit with gravity as the important propelling factor and at the end of that production circuit it loads its sodium chloride products on broad transportation units at its plants.” [Brief for the petitioner, p. 46.]

This position is the fabric of petitioner’s ultimate contention that it is entitled to a depletion allowance computed by taking the permitted percentage of its net sales of all its salt products, and that net sales equal gross income from those sales less returns, allowances, freight, warehousing, and salt purchased for resale. Defendant, on the other hand, maintains that plaintiff’s crude extraction product is brine at the wellhead (in the case of brine wells), and rock salt from the muck pile (in the dry mining operation). If this contention were adopted with its full implications, plaintiff would be restricted to an allowance based upon only that percentage of gross income attributable to the mining of salt to these points and no further. Alternatively, the Government contends that all processes through drying and screening (step 6 for the evaporated salts and step 7 for rock salt, Table 1, supra) are allowable, 6 but that percentages of gross income attributable to the introduction of additives, compressing, and packaging are excluded. For reasons hereinafter set forth, we adopt the latter position.

Depletion at its inception in 1913, 7 was designed to make an allowance for the exhaustion of the mineral resources of a producer on the basis of the market value of the mineral at the mine. In 1918, the Congress authorized the introduction of the “discovery” concept of depletion. 8 In 1926, because the earlier methods created extreme administrative problems relating to the proper methods of determining “value,” the system of percentage depletion was introduced into the computation of allowances with regard to the gas and oil industries. 9 At subsequent intervals other minerals and mining products were added to the approved list of depletable items, sodium chloride being included by section 319 of the Revenue Act of 1951, 65 Stat. 497.

Throughout the long history of depletion, it has been clear that the Congress intended to tax only the income from mining without touching the resources upon which the mine depended. The underlying depletion theory has always been to make an allowance from income for the exhaustion of the wasting assets. United States v. Cannelton Sewer Pipe Co., 364 U.S. 76, 81, 80 S.Ct. 1581, 4 L.Ed.2d 1581 (1960). For that reason it is important in this case to determine with accuracy the cut-off point between “mining” and “manufacturing” in the salt industry. The statute specifies that “mining” includes not just the process of extraction but also the processes normally applied by the miners to prepare their product or products for market. Section 114(b) (4) (B) defines “ordinary treatment processes” by means of inclusion. 10 Although sodium chlo *935 ride is not included as such, we feel that these statutory delineations are helpful in that they indicate the type of processes intended by the Congress to be a part of mining.

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316 F.2d 931, 161 Ct. Cl. 640, 11 A.F.T.R.2d (RIA) 1466, 1963 U.S. Ct. Cl. LEXIS 15, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morton-salt-company-a-corporation-v-the-united-states-cc-1963.