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BURNET v. HARMEL

No. 26.

287 U.S. 103 (1932)

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. HARMEL.

Supreme Court of United States.

Decided November 7, 1932.

Attorney(s) appearing for the Case

Solicitor General Thacher, with whom Assistant Attorney General Youngquist, and Messrs. Whitney North Seymour, Sewall Key, and A.H. Conner were on the brief, for petitioner.

Messrs. Robert Ash and A.H. Britain, with whom Mr. Harry C. Weeks was on the brief, for respondent.

Mr. Walter E. Barton, by leave of Court, filed a brief as amicus curiae.

MR. JUSTICE STONE delivered the opinion of the Court.

Respondent, the owner in fee of Texas oil lands, executed oil and gas leases of the lands for three years and as long thereafter as oil or gas should be produced from them by the lessee, in return for bonus payments aggregating $57,000 in cash, and stipulated royalties, measured by the production of oil and gas by the lessee. In making his income tax returns under the Revenue Act of 1924 for the years 1924 and...

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