Legal Opinion
Sun Company Inc. And Subsidiaries (Consolidated) v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided April 16, 1982No. 81-1997PublishedCited by 15 opinions
1Opinion of the Court
OPINION OF THE COURT
GARTH, Circuit Judge.
In this appeal we are asked to decide whether the costs of drilling offshore exploratory oil and gas wells from mobile rigs are deductible in the year in which they are incurred as “intangible drilling and development costs” under 26 U.S.C. § 263(c) and Treas.Reg. § 1.612-4(a) (“the IDC option”). The Tax Court ruled in favor of the taxpayer, Sun Co., and against the Commissioner, in holding that such drilling costs are immediately deductible under § 1.612-4(a). We agree with the Tax Court’s holding and affirm its decision.
I
Taxpayers in this case are an…
2Cases cited9 opinions
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
- United States v. W. H. CockeCourt of Appeals for the Fifth Circuit · 1968
- Harper Oil Company, a Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1970
- F. H. E. Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
4 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Seligman v. CommissionerUnited States Tax Court · 1985
- Keller v. CommissionerUnited States Tax Court · 1982
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
- Gates Rubber Company, and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1982
- Houston Oil & Minerals Corp. v. CommissionerUnited States Tax Court · 1989
10 more not listed; retrieve them via the Exa API.