Bankline Oil Co. v. Commissioner of Internal Revenue

This is a petition for the review of decisions of the United States Board of Tax Appeals entered March 24, 1936, and March 28, 1936, determining a deficiency in petitioner’s income taxes of $5,108.71 for the year 1927, of which $3,592.88 has been paid leaving a deficiency of $1,515.83, and a deficiency of $846.94 for the year 1930, of which $825.33 has been paid leaving a deficiency of $21.61, and that there was an overpayment of $65.59 -for the year 1928. Petitioner contends that the Board of Tax Appeals should have reduced the deficiency for 1927 by the sum of $2,713.50 and should have determined that there was an overpayment for the year 1928 of $3,598.04 and for the year 1930 of $18,828.04. Petitioner seeks exemption during the taxable year 1930 of all income derived from tide lands situated in the county of Santa Barbara, Cal., which were leased to petitioner 1 by the state of California for the purpose o{ producing oil and gas therefrom. Petitioner also claims that the Board erroneously refused to allow it deductions, for the years 1927, 1928, and 1930 to which it was entitled because of depletion on its, “casinghead gasoline contracts.”

As to petitioner’s first claim of…