S/V Drilling Partners v. Commissioner
United States Tax Court
Sec. 29, I.R.C., provides a credit for fuel produced from nonconventional sources, including gas produced from geopressurized brine, Devonian shale, coal seams, or a tight formation. In 1993 and 1994, S/V, a partnership, sold 32,410 barrels of oil equivalent (BOE's) of natural gas produced from nonconventional sources described under sec. 29, I.R.C.
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Sec. 29, I.R.C., provides a credit for fuel produced from nonconventional sources, including gas produced from geopressurized brine, Devonian shale, coal seams, or a tight formation. In 1993 and 1994, S/V, a partnership, sold 32,410 barrels of oil equivalent (BOE's) of natural gas produced from nonconventional sources described under sec. 29, I.R.C. S/V sold 15,483 BOE's of gas produced from a tight formation that was not Devonian shale and 16,927 BOE's of gas produced from both a tight formation and Devonian shale. HELD: S/V is allowed a credit for 32,410 BOE's of natural gas. The credit…
1Opinion of the Court
OPINION
Colvin, Judge:
On August 3, 1998, respondent issued two notices of final partnership administrative adjustment to S/V Drilling Partners (S/V), a partnership, in which respondent determined adjustments to S/V’s partnership returns for the tax years ending December 31, 1993 and 1994. On August 18, 1998, Snyder Armclar Gas Co. (Snyder), S/V’s tax matters partner, petitioned the Court to redetermine respondent’s adjustments to partnership items.
In 1993 and 1994, S/V sold 32,410 barrels of oil equivalent (boe’s)1 of natural gas produced from nonconventional sources, consisting of 15,483…
2Cases cited12 opinions
- Miller v. Standard Nut Margarine Co. of Fla.Supreme Court of the United States · 1932
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Bernard A. Levin, Phyllis Levin, Alan T. Hrabosky, and Delores Hrabosky v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
- United Telecommunications, Inc. (Formerly United Utilities, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1978
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- Yang Xiang v. Comm'rUnited States Tax Court · 2010