Southwest Exploration Co. v. Commissioner
United States Tax Court
1. Petitioner was granted the drilling and development rights in certain submerged oil property by the State of California. Under the terms of such grant petitioner was required to drill certain offset wells. Upon completion thereof, petitioner was to continue uninterrupted drilling operations until a total of 83 wells were thus drilled.
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1. Petitioner was granted the drilling and development rights in certain submerged oil property by the State of California. Under the terms of such grant petitioner was required to drill certain offset wells. Upon completion thereof, petitioner was to continue uninterrupted drilling operations until a total of 83 wells were thus drilled. Held: The drilling of wells during 1939 to 1943, inclusive, subsequent to the required number of offset wells was a part of the consideration for acquisition of the drilling rights from the State of California and as such the intangible drilling costs…
1Opinion of the Court
Southwest Exploration Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Southwest Exploration Co. v. Commissioner
Docket No. 24872
United States Tax Court
18 T.C. 961; 1952 U.S. Tax Ct. LEXIS 109; 1 Oil & Gas Rep. 1483;
September 10, 1952, Promulgated
Decision will be entered under Rule 50.
1. Petitioner was granted the drilling and development rights in certain submerged oil property by the State of California. Under the terms of such grant petitioner was required to drill certain offset wells. Upon completion thereof, petitioner was to continue uninterrupted drilling operations…
2Cases cited16 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- United States v. CaliforniaSupreme Court of the United States · 1947
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Anderson v. HelveringSupreme Court of the United States · 1940
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
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