Shell Oil Co. v. Commissioner
United States Tax Court
Petitioner is an integrated oil company. Following the enactment of the Crude Oil Windfall Profit Tax Act of 1980, Pub. L. 96-223, 94 Stat. 229, petitioner changed its method of calculating "taxable income from the property" under sec. 613(a), I.R.C. 1954. Consequently, petitioner claimed a net income limitation benefit against its windfall profit tax liability pursuant to sec. 4988(b), I.R.C. 1954, totaling $ 241 million, which respondent disallowed in full.
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Petitioner is an integrated oil company. Following the enactment of the Crude Oil Windfall Profit Tax Act of 1980, Pub. L. 96-223, 94 Stat. 229, petitioner changed its method of calculating "taxable income from the property" under sec. 613(a), I.R.C. 1954. Consequently, petitioner claimed a net income limitation benefit against its windfall profit tax liability pursuant to sec. 4988(b), I.R.C. 1954, totaling $ 241 million, which respondent disallowed in full. Held, petitioner may treat net interest expense incurred in the acquisition of oil and gas properties through one of its wholly owned…
1Opinion of the Court
Shell Oil Company, Petitioner v. Commissioner of Internal Revenue, Respondent *
Shell Oil Co. v. Commissioner
Docket No. 13180-84
United States Tax Court
89 T.C. 371; 1987 U.S. Tax Ct. LEXIS 123; 89 T.C. No. 33; 95 Oil & Gas Rep. 622;
September 1, 1987; As amended October 7, 1987 September 1, 1987, Filed
Decision will be entered under Rule 155.
Petitioner is an integrated oil company. Following the enactment of the Crude Oil Windfall Profit Tax Act of 1980, Pub. L. 96-223, 94 Stat. 229, petitioner changed its method of calculating "taxable income from the property" under sec. 613(a), I.R.C. 1954.…
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