Legal Opinion

Nielson-True Pshp. v. Commissioner

United States Tax Court

Decided September 9, 1997No. Docket Nos. 12069-95, 3980-96Published

P owned an interest in two wells in the same tight formation gas field. The field had been established under statutory procedures as a tight formation field. One well had been certified as producing tight formation gas under the established Federal statutory procedures, and the other had not. Congress provided a tax credit incentive to develop, among other fuels, tight formation gas.

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P owned an interest in two wells in the same tight formation gas field. The field had been established under statutory procedures as a tight formation field. One well had been certified as producing tight formation gas under the established Federal statutory procedures, and the other had not. Congress provided a tax credit incentive to develop, among other fuels, tight formation gas. Sec. 29(c) (2) (A), I.R.C., requires that, as a prerequisite to the credit, "the determination of whether any gas is produced from * * * a tight formation shall be made in accordance with section 503 of the…

1Opinion of the Court

NIELSON-TRUE PARTNERSHIP, TRUE OIL COMPANY, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Nielson-True Pshp. v. Commissioner

Docket Nos. 12069-95, 3980-96

United States Tax Court

109 T.C. 112; 1997 U.S. Tax Ct. LEXIS 57; 109 T.C. No. 6; 138 Oil & Gas Rep. 229;

September 9, 1997, Filed

Decisions will be entered for respondent.

P owned an interest in two wells in the same tight formation gas field. The field had been established under statutory procedures as a tight formation field. One well had been certified as producing tight formation gas under the established…

2Cases cited23 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. United States v. LockeSupreme Court of the United States · 1985
  3. Crane v. CommissionerSupreme Court of the United States · 1947
  4. Commissioner v. BrownSupreme Court of the United States · 1965
  5. Malat v. RiddellSupreme Court of the United States · 1966

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