Shamrock Oil & Gas Corp. v. Commissioner
United States Tax Court
1. Petitioner produced and processed natural gas in which it had an economic interest in its gasoline extraction plants. Based upon the evidence of record, held, for the purpose of determining "gross income from the property" for percentage depletion, the petitioner did not sell gas in the immediate vicinity of the well so that, under the respondent's regulations, the "gross income from the property" is the equivalent of the representative market or field price.
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1. Petitioner produced and processed natural gas in which it had an economic interest in its gasoline extraction plants. Based upon the evidence of record, held, for the purpose of determining "gross income from the property" for percentage depletion, the petitioner did not sell gas in the immediate vicinity of the well so that, under the respondent's regulations, the "gross income from the property" is the equivalent of the representative market or field price. Held, further, the respondent erred in his determination of representative market or field price; proper method established. 2.…
1Opinion of the Court
Tkain, Judge:
Respondent determined deficiencies in the petitioner’s income and excess profits taxes for the years and in the amounts as follows:
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Dochet No. ⅛91⅛5.
The parties have settled the excess profits tax issue and all standard issues other than depletion contained in this docket.
No deficiencies with respect to depletion were found by respondent for the fiscal years ending November 30,1943, through November 30, 1947.
The respondent, as to each of these years, either agreed to the depletion allowance claimed by Shamrock in its returns or he allowed an additional depletion…
2Cases cited49 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Burnet v. HarmelSupreme Court of the United States · 1932
- Sartor v. Arkansas Natural Gas Corp.Supreme Court of the United States · 1944
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
44 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Commissioner v. EngleSupreme Court of the United States · 1984
- United States v. Henderson Clay ProductsCourt of Appeals for the Fifth Circuit · 1963
- The Shamrock Oil & Gas Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
- Hugoton Production Company v. The United StatesUnited States Court of Claims · 1963
23 more not listed; retrieve them via the Exa API.