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PETROLEUM EXPLORATION v. BURNET

No. 448.

288 U.S. 467 (1933)

53 S.Ct. 439

77 L.Ed. 898

PETROLEUM EXPLORATION v. BURNET, COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided March 13, 1933.

Attorney(s) appearing for the Case

Mr. Robert Ash for petitioner.

Assistant Attorney General Youngquist, with whom Solicitor General Thacher, and Messrs. Whitney North Seymour, Sewall Key, and Andrew D. Sharpe were on the brief, for respondent.

By leave of Court, briefs of amici curiae were filed as follows: by Messrs. Thomas R. Dempsey and A. Calder Mackay; by Mr. R.B. Goodell, on behalf of Petroleum Reclamation Corp.; and by Messrs. George W. Wickersham and Clarence Castimore, on behalf of Amerada Corporation.

MR. JUSTICE STONE delivered the opinion of the Court.

Petitioner, a Maine corporation, in making its tax returns of income derived from the operation of oil wells in the years 1925, 1926, and 1927, claimed a deduction from gross income of a depreciation allowance on account of the capitalized costs of drilling the oil wells. The Commissioner refused to allow the deductions and assessed a corresponding deficiency against the taxpayer. On appeal the Board of Tax Appeals...

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