Natomas North America, Inc. v. Commissioner
United States Tax Court
Petitioners owned working interests in the East Binger Unit. In September 1977, a miscible flue-gas injection project was begun. There were 17 injection wells and the injection pattern was an inverted nine-spot pattern with the injection well in the center of a nine-well array. The well density was 160 acres per well. Performance of the project was designed to affect the entire reservoir.
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Petitioners owned working interests in the East Binger Unit. In September 1977, a miscible flue-gas injection project was begun. There were 17 injection wells and the injection pattern was an inverted nine-spot pattern with the injection well in the center of a nine-well array. The well density was 160 acres per well. Performance of the project was designed to affect the entire reservoir. Performance of the project was substantially below that expected due primarily to operational problems and reservoir characteristics significantly different from those initially premised. In May 1978, the…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners’ windfall profit tax as follows:
Docket No. TYE Dec. 31— Taxable quarter ended Deficiency
35928-85 1980 --- $51,103.07
1981 - - - 1272,248.96
6712-86 1981 --- 113,814.13
9/30/81 48,266.61
12/31/81 61,755.78
3/31/82 56,635.11
6/30/82 53,505.46
9/30/82 51,307.75
12/31/82 72,602.61
The issues for our decision are: (1) Whether the miscible flue-gas injection project in the East Binger Unit was significantly expanded within the meaning of section 4993(d)(4)2 so that a portion of the production from the property qualifies as incremental…
2Cases cited4 opinions
- Scott v. CommissionerUnited States Tax Court · 1985
- Page v. CommissionerUnited States Tax Court · 1986
- North Ridge Country Club v. CommissionerUnited States Tax Court · 1987
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
3Cited by9 opinions
- Simon v. Comm'rUnited States Tax Court · 1994
- South Central United Food & Commercial Workers Unions & Employers Health & Welfare Trust v. Appletree Markets, Inc.Court of Appeals for the Fifth Circuit · 1994
- Matter of Appletree Markets, Inc.Court of Appeals for the Fifth Circuit · 1994
- Han v. CommissionerUnited States Tax Court · 1993
- Natomas North America, Inc. v. CommissionerUnited States Tax Court · 1988
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