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Commissioner Vs. Engle
Cites for this judgment
- US Supreme Court
- Jan 10, 1984
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U.S. 206 (1984) U.S. Supreme Court Commissioner v. EngleSearch
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U.S. 206 (1984) Commissioner of Internal Revenue v. EngleSearch
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and accordingly were subject to percentage depletion. See Herring v. CommissionerSearch
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required to recapture their depletion deductions and restore the previously deducted amounts to income. See Douglas v. CommissionerSearch
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always been required to reduce their allowances by any bonuses or advance royalties paid to lessors. See Helvering v. TwinSearch
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NLRB v. LionSearch
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part). The circumstances of the enactment of particular legislation may be particularly relevant to this inquiry, Watt v. AlaskaSearch
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Helvering v. Morgan'sSearch
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Lease bonuses and advance royalties are payments received in advance for oil and gas to be extracted, see Herring v. CommissionerSearch
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National Muffler Dealers Assn., Inc. v. UnitedSearch
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must be upheld. United States v. CorrellSearch
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and we therefore cannot defer to it. United Page 464 U. S. 225 States v. CartwrightSearch
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income arising from their property, including lease bonuses and advance royalties, for the past 50 years. See Herring v. CommissionerSearch
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the Code to allow percentage depletion on all income so long as actual extraction eventually occurs. See Douglas v. CommissionerSearch
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Albemarle Paper Co. v. MoodySearch
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income, we believe it would have addressed our decisions to the contrary more explicitly. See Mastro Plastics Corp. v. NLRBSearch
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and therefore is not entitled to deference. United States v. CartwrightSearch
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a), and it is up to him to choose the method that best implements the statutory mandate. See United States v. CorrellSearch
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their income in the year of receipt. No one questions that taxpayers must do that. See North American Oil Consolidated v. BurnetSearch
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Together with No. 82-774, Farmar et al. v. UnitedSearch
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held that lease bonuses, like advance royalties, were not subject to the allowance for percentage depletion. See Glass v. CommissionerSearch
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Engle v. CommissionerSearch
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Glass v. CommissionerSearch
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and Farmar v. UnitedSearch
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are not refundable to lessees even if no oil or gas is produced from the property. See Shamrock Oil & Gas Corp. v. CommissionerSearch
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Consumer Product Safety Comm'n v. GTESearch
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Southeastern Community College v. DavisSearch
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In Helvering v. TwinSearch
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U. S. 741 , 394 U. S. 749 -750 (1969), quoting Commissioner v. SouthSearch
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Thor Power Tool Co. v. CommissionerSearch
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Fulman v. UnitedSearch
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can be read to accommodate the depletion rule of Herring v. CommissionerSearch
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changes. The Court's easy conclusion that Congress explicitly would have addressed this Court's decisions in Herring v. CommissionerSearch
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producers, it results in an effective subsidy smaller than the one produced by the depletion rule of Herring v. CommissionerSearch
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to entertain the Commissioner's settled administrative interpretations with respect. We recognized in United States v. CartwrightSearch
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allowances for independent producers in other ways, it must have chosen to discard the depletion rule of Herring v. CommissionerSearch
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U.S. Supreme Court Commissioner v. EngleSearch
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Commissioner of Internal Revenue v. EngleSearch
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See Herring v. CommissionerSearch
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See Douglas v. CommissionerSearch
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See Helvering v. TwinSearch
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States v. CartwrightSearch
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