CORRA RESOURCES, LTD. v. C.I.R.

No. 90-3365.

945 F.2d 224 (1991)

CORRA RESOURCES, LTD., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided October 9, 1991.


Attorney(s) appearing for the Case

Arthur H. Boelter, argued, John J. White, Boelter, Silver & Gale, Seattle, Wash., for Corra Resources, Ltd.

Abraham N.M. Shashy, Jr., I.R.S., Gary R. Allen, Jonathan S. Cohen, Christine A. Grant, argued, Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, Washington, D.C., for C.I.R.

Before COFFEY and EASTERBROOK, Circuit Judges, and MORAN, District Judge.


EASTERBROOK, Circuit Judge.

Corra Resources, an investment vehicle for Edwin Corra and his wife Genevieve, put some of its assets into a coal mining lease in 1978. (Corra Plumbing Co., which made the investment, sold its operating assets in 1980 and was renamed as it became an investment company.) Corra Resources obtained from Salem Minerals the right to mine coal in Pikeville, Kentucky (the "Pikeville Quadrangle" lease); it put down $77,500 as prepaid royalties and...

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