North American Oil Consolidated v. Burnet, 286 U.S. 417 (1932), was a landmark decision by the United States Supreme Court that established the claim of right doctrine.

[1] In 1918, North American Oil filed an amended tax return including the profits from the receivership in its 1916 taxable income.

The IRS filed a deficiency, claiming that the income North American Oil gained from receivership should have been taxed in 1917 when they achieved control of it.

North American Oil appealed on the basis that the income was taxable either in 1916 when it was earned, or 1922 when the final decision regarding the land was made, and was granted a writ of certiorari.

[1] The Circuit Court of Appeals held that the profits were taxable to North American Oil as income in 1917 regardless of whether the company’s returns were made on the cash or on the accrual basis.