Shell Oil Company v. Commissioner of Internal Revenue

W. EUGENE DAVIS, Circuit Judge:

Shell Oil Company appeals the adverse judgment of the Tax Court and its computation of “net income from the property” under Treasury Regulation § 1.613-5(a) for purposes of calculating the net income limitation on the windfall profit tax. More particularly, Shell complains of two of the Tax Court’s conclusions. The Tax Court held first that abandoned geological and geophysical costs may not be treated as overhead and allocated among Shell’s mineral properties. It also held that intangible drilling costs must be included in the allocation base for apportioning…