Case Resources
Search this Case
in Google Scholar
on the Web
Google Web Search
MSN Web
Search
Yahoo! Web Search
in the News
Google News Search
Google News Archive
Search
Yahoo! News
Search
in the Blogs
BlawgSearch.com
Search
Google Blog Search
Technorati Blog
Search
in other Databases
Google Book Search
Justia Research Resources
Justia.com
Supreme Court Center
US Regulation Tracker
US District Court Opinions
Federal District Court Civil Case Filings
Legal Blog Search
Legal Podcast Search
USA Constitution Annotated
Online Research Resources
Cornell LII
Cornell Wex Dictionary & Encyclopedia
LLRX.com - Legal Research
Expert Witness Directory
Nolo Consumer & Business
US Court Forms
WashLaw Directory
World LII
Cases Provided By
Creative Commons
public.resource.org
United Salt Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
United States Court of Appeals Fifth Circuit. - 339 F.2d 215
December 7, 1964
Cornelius O. Ryan, Houston, Tex., Kelley, Ryan & Merrill, Houston, Tex., of counsel, for petitioner.
Michael A. Mulroney, Atty., Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Sheldon S. Cohen, Chief Counsel, I.R.S., Eugene F. Colella, Atty., I.R.S., John B. Jones, Jr., Acting Asst. Atty. Gen., Melva M. Graney, Atty., Dept. of Justice, Washington, D. C., for respondent.
Before WISDOM and GEWIN, Circuit Judges, and HANNAY, District Judge.
PER CURIAM.
The Tax Court, in a careful, comprehensive, and well documented opinion, held for the Commissioner: for percentage depletion purposes, the required constructive computation of the taxpayer's "gross income from mining", that is, its gross income from bulk salt (immediately after screening), should be made by multiplying the number of tons of all the salt sold by the average price of the salt sold in bulk form. The taxpayer's average sales price of the sales actually made in bulk form, which constituted a substantial portion of the taxpayer's total sales, may be treated as the representative market price of salt of like kind and grade to the taxpayer's salt. 40 T.C. 359 (1963). We have nothing to add to Judge Mulroney's opinion. The decision is affirmed.