Legal Opinion

Louisiana Land & Exploration Co. v. Commissioner

United States Tax Court

Decided June 27, 1989No. Docket No. 16909-87Published

Petitioner held operating mineral interests from which it carved out overriding royalties that it transferred to a trust for the benefit of its shareholders. Petitioner then distributed to its shareholders units of beneficial interest in the trust.

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Petitioner held operating mineral interests from which it carved out overriding royalties that it transferred to a trust for the benefit of its shareholders. Petitioner then distributed to its shareholders units of beneficial interest in the trust. Held, petitioner did not dispose of "oil, gas, or geothermal property" as that term is defined in sec. 1254, I.R.C. 1954, as amended and in effect in 1983, and is, therefore, not required to "recapture" the IDC previously deducted which related to the subject operating mineral interests.

1Opinion of the Court

Louisiana Land and Exploration Company and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Louisiana Land & Exploration Co. v. Commissioner

Docket No. 16909-87

United States Tax Court

92 T.C. 1340; 1989 U.S. Tax Ct. LEXIS 94; 92 T.C. No. 90; 105 Oil & Gas Rep. 219;

June 27, 1989June 27, 1989, Filed

Decision will be entered under Rule 155.

Petitioner held operating mineral interests from which it carved out overriding royalties that it transferred to a trust for the benefit of its shareholders. Petitioner then distributed to its shareholders units of beneficial interest in…

2Cases cited13 opinions

  1. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  2. Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
  3. Kirby Petroleum Co. v. CommissionerSupreme Court of the United States · 1946
  4. Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
  5. United States v. W. H. CockeCourt of Appeals for the Fifth Circuit · 1968

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