Legal Opinion

Terminal Drilling & Production Co. v. Commissioner

United States Tax Court

Decided July 21, 1959No. Docket No. 65842Published

Petitioner, engaged in the business of drilling oil wells, claimed deductions for drilling expenses it had paid or incurred on some wells that were not completed by the end of its tax-paying periods. Held, under petitioner's method of accounting, expenses of drilling wells could be deducted only in the period when the wells were completed.

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Petitioner, engaged in the business of drilling oil wells, claimed deductions for drilling expenses it had paid or incurred on some wells that were not completed by the end of its tax-paying periods. Held, under petitioner's method of accounting, expenses of drilling wells could be deducted only in the period when the wells were completed. Respondent's disallowance of expenses claimed by petitioner in the fiscal years 1953 and 1954 on wells which were unfinished in those periods is sustained.

1Opinion of the Court

Terminal Drilling & Production Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Terminal Drilling & Production Co. v. Commissioner

Docket No. 65842

United States Tax Court

32 T.C. 926; 1959 U.S. Tax Ct. LEXIS 124; 10 Oil & Gas Rep. 1186;

July 21, 1959, Filed

Decision will be entered for the respondent.

Petitioner, engaged in the business of drilling oil wells, claimed deductions for drilling expenses it had paid or incurred on some wells that were not completed by the end of its tax-paying periods. Held, under petitioner's method of accounting, expenses of drilling wells could be…

2Cases cited4 opinions

  1. Commissioner of Int. Rev. v. Rowan Drilling Co.Court of Appeals for the Fifth Circuit · 1942
  2. Jones, Collector of Internal Revenue v. SmithCourt of Appeals for the Tenth Circuit · 1952
  3. Rowan Drilling Co. v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Terminal Drilling & Production Co. v. CommissionerUnited States Tax Court · 1959

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