Koziara v. Commissioner
United States Tax Court
Petitioners owned land in Michigan under which oil and gas deposits were located. Oil and gas deposits also were located under land adjacent to petitioners' land. The deposits were part of a single, larger reservoir of oil and gas.
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Petitioners owned land in Michigan under which oil and gas deposits were located. Oil and gas deposits also were located under land adjacent to petitioners' land. The deposits were part of a single, larger reservoir of oil and gas. In 1973, the Michigan Supervisor of Wells issued an order under Michigan law (referred to as a unitization order) restricting petitioners and the other owners of land overlaying the oil and gas reservoir from independently extracting oil and gas from the reservoir. Under the unitization order, only Sun Oil Co. was allowed to extract oil and gas from the reservoir,…
1Opinion of the Court
Eugene H. Koziara and Laura A. Koziara, Petitioners v. Commissioner of Internal Revenue, Respondent; Aniela Koziara, Petitioner v. Commissioner of Internal Revenue, Respondent
Koziara v. Commissioner
Docket Nos. 10828-80, 11321-80
United States Tax Court
86 T.C. 999; 1986 U.S. Tax Ct. LEXIS 105; 86 T.C. No. 61; 90 Oil & Gas Rep. 188;
May 21, 1986, Filed
Appropriate orders and decisions will be entered under Rule 155.
Petitioners owned land in Michigan under which oil and gas deposits were located. Oil and gas deposits also were located under land adjacent to petitioners' land. The deposits were part…
2Cases cited9 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Kittle v. CommissionerUnited States Tax Court · 1953
- Wronski v. Sun Oil CompanyMichigan Court of Appeals · 1979
- Otis A. Kittle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
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