Legal Opinion

Gulf Oil Corp. v. Commissioner

United States Tax Court

Decided May 7, 1986No. Docket No. 22499-82Published

Petitioner obtained one-half of the rights to the Kuwait Concession in 1951 entitling it to engage in exploration, development, production, transportation, and marketing of Kuwaiti crude oil.

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Petitioner obtained one-half of the rights to the Kuwait Concession in 1951 entitling it to engage in exploration, development, production, transportation, and marketing of Kuwaiti crude oil. Portions of petitioner's interest were nationalized by Kuwait in 1973 and 1974. The final 20-percent ownership interest of petitioner was nationalized by Kuwait in 1975. The Nationalization Agreement, which had to be approved by the National Assembly of Kuwait, provided that petitioner would be paid $ 25,250,000, an amount equal to the book value of the physical assets excluding the value of the…

1Opinion of the Court

Gulf Oil Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Gulf Oil Corp. v. Commissioner

Docket No. 22499-82

United States Tax Court

86 T.C. 937; 1986 U.S. Tax Ct. LEXIS 110; 86 T.C. No. 56; 89 Oil & Gas Rep. 183;

May 7, 1986, Filed

Petitioner obtained one-half of the rights to the Kuwait Concession in 1951 entitling it to engage in exploration, development, production, transportation, and marketing of Kuwaiti crude oil. Portions of petitioner's interest were nationalized by Kuwait in 1973 and 1974. The final 20-percent ownership interest of petitioner was nationalized by…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. AndersonSupreme Court of the United States · 1926
  3. Gibson Products Co. Kell Blvd. v. United StatesCourt of Appeals for the Fifth Circuit · 1981
  4. Estate of Craft v. CommissionerUnited States Tax Court · 1977
  5. Ciaio v. CommissionerUnited States Tax Court · 1967

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