Burnet v. Coronado Oil & Gas Co.

Status

60 later cases cite Burnet v. Coronado Oil & Gas Co.; 60 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Treatments

Overruled

• The Supreme Court expressly overruled Burnet's exemption for a private lessee's income under a state school-land lease and allowed a nondiscriminatory federal tax on that income.

  Helvering v. Mountain Producers Corp. · Supreme Court of the United States · filed March 7, 1938

  We are convinced that the rulings in Gillespie v. Oklahoma, supra, and Burnet v. Coronado Oil & Gas Co., supra, are out of harmony with correct principle and accordingly they should be, and they now are, overruled.

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Limited

• The Montana Supreme Court confined Burnet's tax-immunity reasoning to lessees whose income came solely from protected lands and permitted tax on a company that also received income elsewhere.

  Santa Rita Oil & Gas Co. v. State Board of Equalization · Supreme Court of Montana · filed January 22, 1936

  It is fairly inferable from a reading of the majority opinions in the cases of Gillespie v. Oklahoma, supra, and Burnet v. Coronado Oil & Gas Co., supra, together, that the rule of the Gillespie Gase will only be applied where the income of an individual or corporation is solely derived from state-owned or restrictively held Indian lands. It appears on the face of the complaint, both of the plaintiff and of the Texas Company, that income was derived by these corporations during the periods of time in question, from other sources.

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