Gates Rubber Co. & Subsidiaries v. Commissioner
United States Tax Court
On petitioners' consolidated Federal income tax returns for the taxable years ending Feb. 26, 1972, and Dec. 29, 1973, deductions were claimed for intangible drilling costs incurred in connection with the drilling of offshore wells with mobile rigs.
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On petitioners' consolidated Federal income tax returns for the taxable years ending Feb. 26, 1972, and Dec. 29, 1973, deductions were claimed for intangible drilling costs incurred in connection with the drilling of offshore wells with mobile rigs. The deductions were disallowed in the statutory notice of deficiency on the ground that such costs did not come within the definition of "intangible drilling and development costs" found in sec. 1.612-4, Income Tax Regs., and that, therefore, such costs should be treated as capital costs of the properties concerned. Held, the intangible expenses…
1Opinion of the Court
Gates Rubber Company and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent
Gates Rubber Co. & Subsidiaries v. Commissioner
Docket No. 4007-77
United States Tax Court
74 T.C. 1456; 1980 U.S. Tax Ct. LEXIS 51; 67 Oil & Gas Rep. 647;
September 25, 1980, Filed
Decision will be entered under Rule 155.
On petitioners' consolidated Federal income tax returns for the taxable years ending Feb. 26, 1972, and Dec. 29, 1973, deductions were claimed for intangible drilling costs incurred in connection with the drilling of offshore wells with mobile rigs. The deductions were disallowed in…
2Cases cited13 opinions
- Newark Morning Ledger Company, a Corporation of the State of New Jersey v. The United States of AmericaCourt of Appeals for the Third Circuit · 1976
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
- Haass v. CommissionerUnited States Tax Court · 1970
- F. H. E. Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
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