# Edwards Drilling Co. v. Commissioner > United States Board of Tax Appeals · January 27, 1937 · 35 B.T.A. 341 URL: https://www.frixlaw.com/law-library/cases/4496276 ## Case - **Full name:** EDWARDS DRILLING COMPANY, v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** January 27, 1937 - **Citations:** 35 B.T.A. 341; 1937 BTA LEXIS 887 - **Precedential status:** Published - **Opinion:** Dissent by Leech - **Judges:** Leech, Disney - **Cited by:** 18 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4496276 ## Opinion text Leech, dissenting: In my opinion, the petitioner in this case occupies a position no different from that of any other purchaser of oil payment contracts. Certainly, it would not be held that a bank purchasing contracts of this character for cash, as is often done, has expended that money as an ordinary and necessary business expense and not as the cost of a capital asset. The use of labor and material, instead of money, in the acquisition of these oil payment contracts, in my iudgment, does not iustify any different conclusion. Burnet v. Logan, 283 U. S. 404 . Any other treatment results in a clear distortion of income,’ as repugnant to the controlling law as it is to common sense. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4496276. Public record. Not legal advice.