Legal Opinion

Sun Co. & Subsidiaries v. Commissioner

United States Tax Court

Decided September 25, 1980No. Docket No. 9559-76Published

On petitioners' consolidated Federal income tax return for the taxable year 1971, 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 return for the taxable year 1971, 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 incurred in drilling each of the wells…

1Opinion of the Court

Sun Company, Inc., and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Sun Co. & Subsidiaries v. Commissioner

Docket No. 9559-76

United States Tax Court

74 T.C. 1481; 1980 U.S. Tax Ct. LEXIS 52; 68 Oil & Gas Rep. 353;

September 25, 1980, Filed

Decision will be entered under Rule 155.

On petitioners' consolidated Federal income tax return for the taxable year 1971, 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…

2Cases cited13 opinions

  1. 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
  2. Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
  3. Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
  4. Haass v. CommissionerUnited States Tax Court · 1970
  5. F. H. E. Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945

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