Legal Opinion
TGS-NOPEC Geophysical Company and Subsidiaries v. Commissioner
United States Tax Court
Decided August 26, 2020No. 28140-14Published
1Opinion of the Court
155 T.C. No. 3
UNITED STATES TAX COURT TGS-NOPEC GEOPHYSICAL COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 28140-14. Filed August 26, 2020. R disallowed P’s claimed I.R.C. sec. 199 deduction of $1,946,324 for the 2008 tax year. R determined that P’s gross receipts from the leasing of processed marine seismic data are not considered domestic production gross receipts (DPGR). Held: P’s processed marine seismic data is not qualifying production property within the meaning of I.R.C. sec. 199(c)(5) because it is neither tangible personal property…
2Cases cited9 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Walt Disney Productions v. United States of America, Walt Disney Productions v. United StatesCourt of Appeals for the Ninth Circuit · 1973
- Texas Instruments Incorporated, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Norwest Corp. v. CommissionerUnited States Tax Court · 1997
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