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BELRIDGE OIL CO. v. COMMISSIONER

Docket No. 54288.

27 T.C. 1044 (1957)

BELRIDGE OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 29, 1957.

Attorney(s) appearing for the Case

John B. Milliken, Esq., and Harrison Harkins, Esq., for the petitioner.

Richard W. Janes, Esq., for the respondent.

This proceeding involves a deficiency in income tax in the amount of $33,879.44 and a deficiency in excess profits tax in the amount of $9,866.88 for the year 1950. Petitioner claims an overpayment of taxes for such year.

The issues to be decided are: (1) Whether, by joining in a unitization agreement for the cooperative operation of all wells in a certain oil pool, petitioner exchanged its separate depletable interest in...

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