Jahn v. Commissioner of Internal Revenue

Decision Date12 April 1973
Docket NumberNo. 72-1976.,72-1976.
Citation475 F.2d 1140
PartiesHarold E. JAHN and Mary Jahn, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.
CourtU.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.

ORDER

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
    • United States
    • FNREL - Special Institute Mining Agreements III (FNREL)
    • Invalid date
    ...(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......

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