Income Tax Keyed to Lind
Cowden v. Commissioner
Frank Cowden, Sr. and his wife made an oil, gas, and mineral lease for them and their children on land in Texas to Stanolind Oil and Gas Company. Stanolind agreed to make supplemental bonus or advance royalty payments of $511,192.50. The payments were a definitive obligation regardless of the production on the lease, and were to be made over several years and not all at once. The Cowdens assigned the payments to First National Bank of Midland for face value less a small discount. The Cowdens reported the amounts received from the assignment as long-term capital gains. The Commissioner of Internal Revenue found that the Cowdens should have been taxed on the full amount regardless of the deferred payment arrangements because they were equivalent to cash.
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