Legal Opinion

Caltex Oil Venture v. Comm'r

United States Tax Court

Decided January 12, 2012No. Docket No. 3793-08Published

C, an accrual-basis partnership, entered into a turnkey contract under which it paid $5,172,666 by cash and note in December 1999 for the drilling of two oil and gas wells.

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C, an accrual-basis partnership, entered into a turnkey contract under which it paid $5,172,666 by cash and note in December 1999 for the drilling of two oil and gas wells. Although some site preparation required under the contract occurred in 1999, no drill penetrated the ground for purposes of drilling a well by or on behalf of C within 90 days after the end of 1999. C claimed a full deduction for the $5,172,666 as intangible drilling costs (IDCs) on its 1999 Federal tax return. R issued a notice of final partnership administrative adjustment to P, C's tax matters partner, determining,…

1Opinion of the Court

CALTEX OIL VENTURE, CALTEX MANAGEMENT CORPORATION, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Caltex Oil Venture v. Comm'r

Docket No. 3793-08.

United States Tax Court

138 T.C. 18; 2012 U.S. Tax Ct. LEXIS 2; 138 T.C. No. 2; 176 Oil & Gas Rep. 325;

January 12, 2012, Filed

An appropriate order will be issued.

C, an accrual-basis partnership, entered into a turnkey contract under which it paid $5,172,666 by cash and note in December 1999 for the drilling of two oil and gas wells. Although some site preparation required under the contract occurred in 1999, no drill…

2Cases cited49 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Almendarez-Torres v. United StatesSupreme Court of the United States · 1998
  3. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  4. Caminetti v. United StatesSupreme Court of the United States · 1917
  5. Perrin v. United StatesSupreme Court of the United States · 1979

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