Legal Opinion

Green Gas Del. Statutory Trust v. Comm'r

United States Tax Court

Decided July 14, 2016No. Docket Nos. 26965-09, 13698-10, 14409-10PublishedCited by 7 opinions

Ps are the tax matters partners for G and N, Delaware statutory trusts that were purportedly involved in the production and sales of landfill gas to RTC, which had entered into landfill license agreements with the owners and operators of 24 landfills.

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Ps are the tax matters partners for G and N, Delaware statutory trusts that were purportedly involved in the production and sales of landfill gas to RTC, which had entered into landfill license agreements with the owners and operators of 24 landfills. G claimed credits for producing fuel from a nonconventional source under I.R.C. sec. 45K (and its predecessor, I.R.C. sec. 29) with respect to landfill gas asserted to have been produced from 23 landfills in 2005, 2006, and 2007. N claimed such credits for one landfill for 2006 and 2007. The 24 landfills had varying degrees of equipment,…

1Opinion of the Court

GREEN GAS DELAWARE STATUTORY TRUST, METHANE BIO, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent1

Green Gas Del. Statutory Trust v. Comm'r

Docket Nos. 26965-09, 13698-10, 14409-10

United States Tax Court

147 T.C. 1; 2016 U.S. Tax Ct. LEXIS 17; 147 T.C. No. 1;

July 14, 2016, Filed

Green Gas Del. Statutory Trust v. Comm'r, T.C. Memo 2015-168, 2015 Tax Ct. Memo LEXIS 167 (T.C., 2015)

An appropriate order will be issued, and decisions will be entered under Rule 155.

Ps are the tax matters partners for G and N, Delaware statutory trusts that were purportedly involved…

2Cases cited62 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  5. Chrysler Corp. v. BrownSupreme Court of the United States · 1979

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3Cited by7 opinions

  1. Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
  2. Green Gas Del. Statutory Trust v. Comm'r of Internal Revenue Serv.Court of Appeals for the D.C. Circuit · 2018
  3. Roth v. C.I.R.Court of Appeals for the Tenth Circuit · 2019
  4. Wages v. Comm'rUnited States Tax Court · 2017
  5. Ampersand Chowchilla Biomass, LLC v. United StatesUnited States Court of Federal Claims · 2020

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