Southland Royalty Co. v. United States

OPINION

FUTEY, Judge.

This tax case is before the court on cross-motions for partial summary judgment pursuant to RUSCC 56. Plaintiff, Southland Royalty Company (Southland), seeks a refund of $17,333,294.96 in federal income taxes paid, plus $19,250,403.70 in assessed interest, for the calendar year 1980.1 Plaintiff contends that the Internal Revenue Service (IRS) erroneously required Southland to recapture previously deducted intangible drilling and development costs (IDCs) after the transfer of nonoperating mineral property interests to shareholder trusts. Defendant maintains that plaintiffs…