Grynberg v. Commissioner
United States Tax Court
83 T.C. 255 (1984)
- Written by Bradley Marzola, JD
Facts
Jack Grynberg (plaintiff) owned many oil and gas leases across five states. Each of the leases contained a delay clause. Under the delay clause, Grynberg would owe an annual fee to be paid in the anniversary month of the specific lease if drilling operations did not occur. If Grynberg did not pay this fee promptly, the lease would automatically revert back to the owner. For all leases with an anniversary date between April and December, Grynberg paid the delay-clause fee one month before it was due. For all leases with an anniversary date between January and March, Grynberg paid the delay-clause fee in December of the prior year. Grynberg utilized the cash-basis method of accounting for tax purposes and recognized all of his expenses and gains at the time of actual payment or receipt. Grynberg deducted the January through March delay-clause payments in the prior year’s federal taxes. The commissioner of internal revenue (commissioner) (defendant) determined that the February and March delay-clause payments should be deducted in the year they were due. Grynberg petitioned the United States Tax Court for a redetermination.
Rule of Law
Issue
Holding and Reasoning (Swift, J.)
What to do next…
Here's why 811,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
