Mesa Petroleum Co. v. Commissioner
United States Tax Court
Petitioner operated gas properties under leases calling for it to pay its lessors one-eighth of the proceeds from the actual sale of the gas and its products, reduced by an aliquot share of the costs of transporting, processing, and marketing the gas. The parties have stipulated the representative market or field price for the gas at the wellhead.
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Petitioner operated gas properties under leases calling for it to pay its lessors one-eighth of the proceeds from the actual sale of the gas and its products, reduced by an aliquot share of the costs of transporting, processing, and marketing the gas. The parties have stipulated the representative market or field price for the gas at the wellhead. Held, petitioner must compute its percentage depletion allowance under sec. 613, I.R.C. 1954, on the basis of the amount remaining after the gross income from the property, calculated under the representative market or field price method, has been…
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for 1965 in the amount of $208,506.63. Most of the issues have been settled; the only issue remaining for decision is the proper amount of petitioner’s percentage depletion deduction under section 613.1
FINDINGS OE PACT
Mesa Petroleum Co., a corporation chartered Under the laws of Delaware, has its principal office at Amarillo, Tex. It is the surviving corporation of a merger, on April 30, 1969, with Hugoton Production Co. (hereinafter referred to as Hugoton). Plugoton was also chartered under the laws of…
2Cases cited19 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Thomas v. PerkinsSupreme Court of the United States · 1937
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3Cited by3 opinions
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
- Mesa Petroleum Co. v. CommissionerUnited States Tax Court · 1972