United Salt Corporation v. Commissioner of Internal Revenue

Fifth Circuit

United Salt Corporation v. Commissioner of Internal Revenue

339 F.2d 215, 14 A.F.T.R.2d (RIA) 6085, 1964 U.S. App. LEXIS 3680

CourtCourt of Appeals for the Fifth Circuit

DecidedDecember 7, 1964

Docket21311_1

StatusPublished

Cited by3 cases

This text of 339 F.2d 215 (United Salt Corporation 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

United Salt Corporation v. Commissioner of Internal Revenue, 339 F.2d 215, 14 A.F.T.R.2d (RIA) 6085, 1964 U.S. App. LEXIS 3680 (5th Cir. 1964).

Pincite

Opinion

PER CURIAM.

The Tax Court, in a careful, comprehensive, and well documented opinion,, held for the Commissioner: for percentage depletion purposes, the required, constructive computation of the taxpayer’s “gross income from mining”, that is,, its gross income from bulk salt (immediately after screening), should be made by multiplying the number of tons of all the salt sold by the average price of the salt sold in bulk form. The taxpayer’s average sales price of the sales actually made in bulk form, which constituted a substantial portion of the taxpayer’s total sales, may be treated as the representative market price of salt of like kind and grade to the taxpayer’s salt. 40 T.C. 359 (1963). We have nothing to add to Judge Mulroney’s opinion. The decision is affirmed.

Free access — add to your briefcase to read the full text and ask questions with AI

PER CURIAM.

The Tax Court, in a careful, comprehensive, and well documented opinion,, held for the Commissioner: for percentage depletion purposes, the required, constructive computation of the taxpayer’s “gross income from mining”, that is,, its gross income from bulk salt (immediately after screening), should be made by multiplying the number of tons of all the salt sold by the average price of the salt sold in bulk form. The taxpayer’s average sales price of the sales actually made in bulk form, which constituted a substantial portion of the taxpayer’s total sales, may be treated as the representative market price of salt of like kind and grade to the taxpayer’s salt. 40 T.C. 359 (1963). We have nothing to add to Judge Mulroney’s opinion. The decision is affirmed.

United States v. California Portland Cement Company, a Corporation, Successor-In-Interest to Arizona Portland Cement Company, a Corporation, California Portland Cement Company, a Corporation, Successor-In-Interest to Arizona Portland Cement Company, a Corporation, Cross-Appellee v. United States of America, Cross-Appellant. United States of America v. California Portland Cement Company, California Portland Cement Company, Cross-Appellant v. United States of America, Cross-Appellee

413 F.2d 161 (Ninth Circuit, 1969)

United States v. California Portland Cement Co.

413 F.2d 161 (Ninth Circuit, 1969)

Cite This Page — Counsel Stack

Bluebook (online)

339 F.2d 215, 14 A.F.T.R.2d (RIA) 6085, 1964 U.S. App. LEXIS 3680, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-salt-corporation-v-commissioner-of-internal-revenue-ca5-1964.

Opinion

Related

Cite This Page — Counsel Stack