Jahn v. Commissioner of Internal Revenue
Decision Date | 12 April 1973 |
Docket Number | No. 72-1976.,72-1976. |
Citation | 475 F.2d 1140 |
Parties | Harold E. JAHN and Mary Jahn, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. |
Court | U.S. Court of Appeals — Sixth Circuit |
Leonard J. Simasko, Mt. Clemens, Mich., for appellants.
Wesley J. Filer, Atty., Tax Div., Dept. of Justice, Washington, D. C., for appellee; Scott P. Crampton, Asst. Atty. Gen., Thomas L. Stapleton, Grant W. Wiprud, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief.
Before WEICK and PECK, Circuit Judges, and CECIL, Senior Circuit Judge.
Upon consideration, it is ordered that the decision of the Tax Court be and it is hereby affirmed on the opinion of Judge Withey, 58 T.C. 452.
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CHAPTER 4 FEDERAL PARTNERSHIP TAX TREATMENT IN MINING AGREEMENTS: SELECTED BASIC CONCEPTS
...(royalties paid with nonrecourse notes did not qualify as advance minimum royalties). [52] See Jahn v. Comm., 58 T.C. 452 (1972) affd, 475 F.2d 1140 (6th CIr. 1973) (transfer of three-eights mineral interest for lump sum payment, but with operating costs to be borne in part by the transfero......