Arkansas-Oklahoma Gas Co. v. Commissioner
United States Tax Court
For 1944 and 1945, petitioner claims deductions for amortization of the intangible drilling and development costs of three gas wells under section 124 of the Code. A Necessity Certificate had been issued in 1941 with respect to such wells. Respondent denied this deduction, and allowed some depletion in lieu thereof on the theory that such costs are not subject to amortization, but are covered by section 23 (m) of the Code.
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For 1944 and 1945, petitioner claims deductions for amortization of the intangible drilling and development costs of three gas wells under section 124 of the Code. A Necessity Certificate had been issued in 1941 with respect to such wells. Respondent denied this deduction, and allowed some depletion in lieu thereof on the theory that such costs are not subject to amortization, but are covered by section 23 (m) of the Code. Held, intangible drilling and development costs of a natural resource are not deductible under section 124 of the Code providing for special amortization of emergency…
1Opinion of the Court
Arkansas-Oklahoma Gas Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Arkansas-Oklahoma Gas Co. v. Commissioner
Docket Nos. 27711, 27712
United States Tax Court
17 T.C. 1208; 1952 U.S. Tax Ct. LEXIS 288; 1 Oil & Gas Rep. 213;
January 23, 1952, Promulgated
Decision will be entered under Rule 50.
For 1944 and 1945, petitioner claims deductions for amortization of the intangible drilling and development costs of three gas wells under section 124 of the Code. A Necessity Certificate had been issued in 1941 with respect to such wells. Respondent denied this deduction, and allowed…
2Cases cited4 opinions
- Choate v. CommissionerSupreme Court of the United States · 1945
- Arkansas-Oklahoma Gas Co. v. CommissionerUnited States Tax Court · 1952
- Corona Coal Co. v. United StatesDistrict Court, N.D. Alabama · 1927
- United States v. Corona Coal Co.Court of Appeals for the Fifth Circuit · 1928