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ARKANSAS-OKLAHOMA GAS CO. v. COMMISSIONER OF INT. REV.

Nos. 14635, 14636.

201 F.2d 98 (1953)

ARKANSAS-OKLAHOMA GAS CO. v. COMMISSIONER OF INTERNAL REVENUE (two cases).

United States Court of Appeals Eighth Circuit.

January 20, 1953.

Attorney(s) appearing for the Case

Harry P. Daily, Ft. Smith, Ark. (John P. Woods and J. S. Daily, Ft. Smith, Ark., were with him on the brief), for petitioner.

Harry Marselli, Sp. Asst. to the Atty. Gen. (Charles S. Lyon, Acting Asst. Atty. Gen., and Ellis N. Slack and Louise Foster, Sp. Assts. to the Atty. Gen., were on the brief), for respondent.

Before SANBORN, JOHNSEN, and RIDDICK, Circuit Judges.

RIDDICK, Circuit Judge.

These petitions challenge decisions of the Tax Court affirming the Commissioner's determinations of deficiencies in the petitioner's income taxes for the years 1944 and 1945. The facts are stipulated. The sole question is one of statutory interpretation. It is whether, pursuant to section 124(a) of the Internal Revenue Code, the petitioner has the right to amortize and deduct intangible costs incurred in the development of three natural gas...

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