Keller v. Commissioner
United States Tax Court
In 1973, K acquired a $ 50,000 limited partnership interest in an oil and gas drilling program sponsored by Amarex, Inc. Issue 1: The drilling partnership participated in the drilling of 182 wells, approximately two-thirds of which were drilled pursuant to pay-as-you-go contracts, and the balance, pursuant to contracts prepaid in December 1973. The drilling partnership elected to expense certain items as intangible drilling costs (IDC) under sec. 263(c), I.R.C. 1954.…
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In 1973, K acquired a $ 50,000 limited partnership interest in an oil and gas drilling program sponsored by Amarex, Inc. Issue 1: The drilling partnership participated in the drilling of 182 wells, approximately two-thirds of which were drilled pursuant to pay-as-you-go contracts, and the balance, pursuant to contracts prepaid in December 1973. The drilling partnership elected to expense certain items as intangible drilling costs (IDC) under sec. 263(c), I.R.C. 1954. Respondent accepted the IDC classification. He also allowed deductions in 1973 for amounts paid in 1973 on the pay-as-you-go…
1Opinion of the Court
Stephen A. Keller and Ethel L. Keller, Petitioners v. Commissioner of Internal Revenue, Respondent
Keller v. Commissioner
Docket No. 2656-79
United States Tax Court
79 T.C. 7; 1982 U.S. Tax Ct. LEXIS 68; 79 T.C. No. 2; 74 Oil & Gas Rep. 127;
July 8, 1982, Filed
Decision will be entered under Rule 155.
In 1973, K acquired a $ 50,000 limited partnership interest in an oil and gas drilling program sponsored by Amarex, Inc.
Issue 1: The drilling partnership participated in the drilling of 182 wells, approximately two-thirds of which were drilled pursuant to pay-as-you-go contracts, and the balance,…
Also in this document: Concurrence; Concurring in part, dissenting in part.
2Cases cited74 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Remmer v. United StatesSupreme Court of the United States · 1954
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
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