Clajon Gas Co., L.P. v. Comm'r
United States Tax Court
Partnership C owned and operated natural gas gathering systems to transport gas purchased from natural gas producers. C treated certain pipeline and related components of the gathering systems as natural gas production assets within asset class 13.2 of Rev. Proc. 87-56, 1987-2 C.B. 674, with a 7-year recovery period.
Read the full summary
Partnership C owned and operated natural gas gathering systems to transport gas purchased from natural gas producers. C treated certain pipeline and related components of the gathering systems as natural gas production assets within asset class 13.2 of Rev. Proc. 87-56, 1987-2 C.B. 674, with a 7-year recovery period. Held: Because C's use of its gathering systems determines the proper asset class, and because C was not a "natural gas producer", the components in question are not within asset class 13.2; rather, they are used by C to transport gas and are, therefore, within asset class 46.0,…
1Opinion of the Court
Halpern, Judge:
By notices of final partnership administrative adjustment dated April 28, 1997, respondent made adjustments to partnership returns filed by Clajon Gas Co., L.P. (Clajon), for taxable years ending December 31, 1990, September 25, 1991, December 31, 1991, and June 30, 1992 (the audit years). Taking into account issues and items resolved by the parties, the sole adjustments in dispute are respondent’s adjustments reducing Clajon’s deduction for “pipeline depreciation”, as follows:
TYE Adjustment
12/31/90 . $7,920,799
9/25/91 . 19,644,092
12/31/91 . 4,372,916
6/30/92 . 12,187,347
The…
2Cases cited4 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Nicklaus v. Comm'rUnited States Tax Court · 2001
- Duke Energy Natural Gas Corp. v. CommissionerCourt of Appeals for the Tenth Circuit · 1999
- Duke Energy Natural Gas Corp. v. CommissionerUnited States Tax Court · 1997
3Cited by8 opinions
- Mendes v. Comm'rUnited States Tax Court · 2003
- PPL Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 2010
- Saginaw Bay Pipeline Company, Cms Saginaw Bay Company, Saginaw Bay Lateral Company, and Cms Saginaw Bay Lateral Company v. United StatesCourt of Appeals for the Sixth Circuit · 2003
- Clajon Gas Co., L.P. v. Comm'rUnited States Tax Court · 2002
- Clajon Gas Co., L.P., Aquila Gas Pipeline Corp., Tax Matters Partner v. CommissionerUnited States Tax Court · 2002
3 more not listed; retrieve them via the Exa API.