Legal Opinion
Arthur E. Reich v. Commissioner of Internal Revenue, George D. Rowan v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 21, 1972No. 25902, 25903PublishedCited by 12 opinions
1Opinion of the Court
WRIGHT, Circuit Judge:
These appeals from Tax Court decisions present two questions: (1) Are the taxpayers’ reserves of geothermal steam an exhaustible natural resource? (2) Is geothermal steam a “gas” within the meaning of Internal Revenue Code §§ 263(c), 611(a), and 613(b), which allow a percentage depletion deduction for the intangible costs of drilling and developing oil and gas wells ?
The Tax Court held in favor of the taxpayers on each question. Reich v. Commissioner, 52 T.C. 700 (1969) and Rowan v. Commissioner, 28 Tax Ct. Mem. 797 (1969). The Commissioner appeals. We affirm.
Taxpayers…
2Cases cited2 opinions
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Reich v. CommissionerUnited States Tax Court · 1969
3Cited by12 opinions
- Joe Aulston and Lola Aulston v. United States of America, and Shell Western E & P, Intervenors-AppelleesCourt of Appeals for the Tenth Circuit · 1990
- United States v. Union Oil Company of CaliforniaCourt of Appeals for the Ninth Circuit · 1977
- Geothermal Kinetics, Inc. v. Union Oil Co.California Court of Appeal · 1977
- Pariani v. State of CaliforniaCalifornia Court of Appeal · 1980
- Victory Sand & Concrete, Inc. v. CommissionerUnited States Tax Court · 1974
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