Gulf Oil Corp. v. Commissioner
United States Tax Court
Petitioner designed, constructed, transported, and installed self-contained drilling and production platforms on properties in the Gulf of Mexico and the North Sea.
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Petitioner designed, constructed, transported, and installed self-contained drilling and production platforms on properties in the Gulf of Mexico and the North Sea. In the process of design and construction, costs were incurred that petitioner seeks to deduct as intangible drilling costs (IDC) under sec. 263, Internal Revenue Code of 1954. Each of the platforms was designed for a useful life of approximately 20 years at the conclusion of which period each platform would have no salvage value to petitioner. Held, the costs incurred are deductible as IDC as they were not incurred in the…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, with the approval of the Court, agreed that certain issues would be severed and tried at a special trial session which was held at Dallas, Texas.
One of the issues to be tried was designated by the parties as the “Intangible Drilling and Development Costs” issue. The issue for decision is whether petitioner may deduct as IDC under section 263(c),1 certain costs…
2Cases cited16 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Harper Oil Company, a Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1970
11 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1987
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
- Houston Oil & Minerals Corp. v. CommissionerUnited States Tax Court · 1989
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1989
8 more not listed; retrieve them via the Exa API.