GRISON OIL CORPORATION v. COMMISSIONER OF INT. REV.

Nos. 1632, 1633.

96 F.2d 125 (1938)

GRISON OIL CORPORATION v. COMMISSIONER OF INTERNAL REVENUE. ROGERS OIL & GAS CO. v. SAME.

Circuit Court of Appeals, Tenth Circuit.

April 11, 1938.


Attorney(s) appearing for the Case

Chas. H. Garnett, of Oklahoma City, Okl., for petitioners.

Warren F. Wattles, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key and L. W. Post, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before LEWIS, BRATTON, and WILLIAMS, Circuit Judges.


BRATTON, Circuit Judge.

These petitions for review of redeterminations of the Board of Tax Appeals present the common question whether a taxpayer may deduct from gross income as ordinary business expense the amount of intangible costs under a so-called turnkey contract for a drilled and equipped oil well where such amount is segregated from the cost of the equipment and physical property of the well.

The taxpayer in the first case owned an undivided interest...

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