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JAMES PETROLEUM CORP. v. COMMISSIONER OF INT. REV.

No. 28, Docket 24083.

238 F.2d 678 (1956)

JAMES PETROLEUM CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided November 13, 1956.

Attorney(s) appearing for the Case

Watson Washburn, of Washburn & Gray, New York City, for petitioner.

Melva M. Graney, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and Hilbert P. Zarky, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before CLARK, Chief Judge, and L. HAND and SWAN, Circuit Judges.

CLARK, Chief Judge.

This petition for review of a decision of the Tax Court, 24 T.C. 509, assessing deficiencies against the petitioner-taxpayer in its income taxes for 1947 and 1948 raises issues as to the disallowance of its claimed deductions for losses of oil royalty interests and for depletion of such interests. On the first point petitioner contests the conclusion of the Tax Court that oil royalties which it sold for a nominal...

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