Legal Opinion

Louisiana Land & Exploration Co. v. Commissioner

United States Tax Court

Decided January 19, 1994No. Docket No. 10246-89Published

P is an affiliated group of corporations engaged primarily in exploration for, and development, production, refining, and sale of, oil and natural gas and exploration for, and production and mining of, other minerals. On Jan. 25, 1980, P entered into a joint operating agreement with 11 other participants to exploit certain oil and gas deposits in the North Brae development area of the North Sea.

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P is an affiliated group of corporations engaged primarily in exploration for, and development, production, refining, and sale of, oil and natural gas and exploration for, and production and mining of, other minerals. On Jan. 25, 1980, P entered into a joint operating agreement with 11 other participants to exploit certain oil and gas deposits in the North Brae development area of the North Sea. Under the joint operating agreement, P received a working interest in the oil and gas deposits. The exploitation of the oil and gas deposits required the construction, transportation, and installation…

1Opinion of the Court

Louisiana Land and Exploration Company and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Louisiana Land & Exploration Co. v. Commissioner

Docket No. 10246-89

United States Tax Court

102 T.C. 21; 1994 U.S. Tax Ct. LEXIS 1; 102 T.C. No. 2; 128 Oil & Gas Rep. 188;

January 19, 1994, Filed

Decision will be entered under Rule 155.

P is an affiliated group of corporations engaged primarily in exploration for, and development, production, refining, and sale of, oil and natural gas and exploration for, and production and mining of, other minerals. On Jan. 25, 1980, P entered into a…

2Cases cited11 opinions

  1. Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
  2. Union Carbide Corp. v. CommissionerUnited States Tax Court · 1980
  3. Union Carbide Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
  4. Exxon Corp. v. United StatesUnited States Court of Claims · 1976
  5. Barton Mines Corporation, and Cross-Appellee v. Commissioner of Internal Revenue, and Cross-AppellantCourt of Appeals for the Second Circuit · 1971

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