Legal Opinion

S/V Drilling Partners v. Commissioner

United States Tax Court

Decided February 23, 2000No. 14163-98Published

Sec. 29, I.R.C., provides a credit for fuel produced from nonconventional sources, including gas produced from geopressurized brine, Devonian shale, coal seams, or a tight formation. In 1993 and 1994, S/V, a partnership, sold 32,410 barrels of oil equivalent (BOE's) of natural gas produced from nonconventional sources described under sec. 29, I.R.C.

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Sec. 29, I.R.C., provides a credit for fuel produced from nonconventional sources, including gas produced from geopressurized brine, Devonian shale, coal seams, or a tight formation. In 1993 and 1994, S/V, a partnership, sold 32,410 barrels of oil equivalent (BOE's) of natural gas produced from nonconventional sources described under sec. 29, I.R.C. S/V sold 15,483 BOE's of gas produced from a tight formation that was not Devonian shale and 16,927 BOE's of gas produced from both a tight formation and Devonian shale. HELD: S/V is allowed a credit for 32,410 BOE's of natural gas. The credit…

1Opinion of the Court

S/V DRILLING PARTNERS, SNYDER ARMCLAR GAS COMPANY, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

S/V Drilling Partners v. Commissioner

No. 14163-98

United States Tax Court

114 T.C. 83; 2000 U.S. Tax Ct. LEXIS 4; 114 T.C. No. 4; 144 Oil & Gas Rep. 582;

February 23, 2000, Filed

Decision will be entered under Rule 155.

Sec. 29, I.R.C., provides a credit for fuel

produced from nonconventional sources, including gas

produced from geopressurized brine, Devonian shale,

coal seams, or a tight formation.

In 1993 and 1994, S/V, a partnership, sold 32,410

barrels of oil equivalent…

2Cases cited18 opinions

  1. Miller v. Standard Nut Margarine Co. of Fla.Supreme Court of the United States · 1932
  2. United States v. MerriamSupreme Court of the United States · 1923
  3. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  4. United States v. Skelly Oil Co.Supreme Court of the United States · 1969
  5. HCSC-Laundry v. United StatesSupreme Court of the United States · 1981

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