Shamrock Oil & Gas Corp. v. Commissioner
United States Tax Court
1. Petitioner produced and processed natural gas in which it had an economic interest in its gasoline extraction plants. Based upon the evidence of record, held, for the purpose of determining "gross income from the property" for percentage depletion, the petitioner did not sell gas in the immediate vicinity of the well so that, under the respondent's regulations, the "gross income from the property" is the equivalent of the representative market or field price.
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1. Petitioner produced and processed natural gas in which it had an economic interest in its gasoline extraction plants. Based upon the evidence of record, held, for the purpose of determining "gross income from the property" for percentage depletion, the petitioner did not sell gas in the immediate vicinity of the well so that, under the respondent's regulations, the "gross income from the property" is the equivalent of the representative market or field price. Held, further, the respondent erred in his determination of representative market or field price; proper method established. 2.…
1Opinion of the Court
The Shamrock Oil and Gas Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Shamrock Oil & Gas Corp. v. Commissioner
Docket Nos. 49145, 61315, 68580, 77791
United States Tax Court
35 T.C. 979; 1961 U.S. Tax Ct. LEXIS 198; 13 Oil & Gas Rep. 1090;
March 24, 1961, Filed
Decisions will be entered under Rule 50.
1. Petitioner produced and processed natural gas in which it had an economic interest in its gasoline extraction plants. Based upon the evidence of record, held, for the purpose of determining "gross income from the property" for percentage depletion, the petitioner did not…
2Cases cited53 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Burnet v. HarmelSupreme Court of the United States · 1932
- Sartor v. Arkansas Natural Gas Corp.Supreme Court of the United States · 1944
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
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