Gulf Oil Corp. v. Commissioner
United States Tax Court
Petitioner designed, constructed, transported, and installed self-contained drilling and production platforms on properties in the Gulf of Mexico and the North Sea.
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Petitioner designed, constructed, transported, and installed self-contained drilling and production platforms on properties in the Gulf of Mexico and the North Sea. In the process of design and construction, costs were incurred that petitioner seeks to deduct as intangible drilling costs (IDC) under sec. 263, Internal Revenue Code of 1954. Each of the platforms was designed for a useful life of approximately 20 years at the conclusion of which period each platform would have no salvage value to petitioner. Held, the costs incurred are deductible as IDC as they were not incurred in the…
1Opinion of the Court
Gulf Oil Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Gulf Oil Corp. v. Commissioner
Docket No. 22499-82
United States Tax Court
87 T.C. 324; 1986 U.S. Tax Ct. LEXIS 67; 87 T.C. No. 20; 91 Oil & Gas Rep. 180;
August 11, 1986, Filed
Petitioner designed, constructed, transported, and installed self-contained drilling and production platforms on properties in the Gulf of Mexico and the North Sea. In the process of design and construction, costs were incurred that petitioner seeks to deduct as intangible drilling costs (IDC) under sec. 263, Internal Revenue Code of 1954. Each…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Harper Oil Company, a Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1970
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