Texaco Inc. v. Commissioner
United States Tax Court
Held, as of April 1980, the term "tar sands", for purposes of the alternative fuel production credit under sec. 44D, I.R.C., consisted of the several rock types that contain an extremely viscous hydrocarbon which is not recoverable in its natural state by conventional oil well production methods including currently used enhanced recovery techniques. See Federal Energy Administration Ruling 1976-4, 41 Fed. Reg. 25886 (June 23, 1976).
1Opinion of the Court
Whitaker, Judge:
A notice of deficiency for the years 1979, 1980, 1981, and 1982 was issued by respondent and was timely mailed to petitioners on July 31, 1989. Petitioners timely filed a petition herein contesting the deficiencies in tax determined by the Commissioner and claiming a refund of certain income tax overpayments plus interest as allowed by law. The issue for decision is the definition of “tar sands” for purposes of section 44D(c)(l)(A).1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.2 The stipulation of facts, supplemental stipulation of facts, and…
2Cases cited20 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
- Atlantic Cleaners & Dyers, Inc. v. United StatesSupreme Court of the United States · 1932
- Commissioner v. BrownSupreme Court of the United States · 1965
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
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3Cited by14 opinions
- Shell Petroleum, Inc., and Subsidiary Corporations v. United StatesCourt of Appeals for the Third Circuit · 1999
- City of New York v. CommissionerUnited States Tax Court · 1994
- Nielson-True Pshp. v. CommissionerUnited States Tax Court · 1997
- Shell Petroleum, Inc. v. United StatesDistrict Court, D. Delaware · 1997
- Shell Petroleum, Inc. v. United StatesUnited States Court of Federal Claims · 2001
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