CGG Ams., Inc. v. Comm'r
United States Tax Court
P conducted marine surveys of the outer continental shelf in the Gulf of Mexico. The surveys employed geophysical techniques, such as seismic reflection, for detecting the presence of oil and gas. P licensed the data from the surveys to its customers on a nonexclusive basis. P's customers used the data to drill for oil and gas on the outer continental shelf in the Gulf of Mexico.
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P conducted marine surveys of the outer continental shelf in the Gulf of Mexico. The surveys employed geophysical techniques, such as seismic reflection, for detecting the presence of oil and gas. P licensed the data from the surveys to its customers on a nonexclusive basis. P's customers used the data to drill for oil and gas on the outer continental shelf in the Gulf of Mexico. R contends that the expenses P incurred in conducting the surveys were not "geological and geophysical expenses paid or incurred in connection with the exploration for, or development of, oil or gas" within the…
1Opinion of the Court
CGG AMERICAS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
CGG Ams., Inc. v. Comm'r
Docket No. 25097-10
United States Tax Court
147 T.C. 78; 2016 U.S. Tax Ct. LEXIS 18; 147 T.C. No. 2;
July 21, 2016, Filed
An appropriate order will be issued granting petitioner's motion for summary judgment and denying respondent's cross-motion for summary judgment, and decision will be entered under Tax Court Rule of Practice & Procedure 155.
P conducted marine surveys of the outer continental shelf in the Gulf of Mexico. The surveys employed geophysical techniques, such as seismic reflection,…
2Cases cited27 opinions
- Oncale v. Sundowner Offshore Services, Inc.Supreme Court of the United States · 1998
- Palmer v. BenderSupreme Court of the United States · 1932
- United States v. LudeySupreme Court of the United States · 1927
- Weiss v. StearnSupreme Court of the United States · 1924
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
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