Nielson-True Pshp. v. Commissioner
United States Tax Court
P owned an interest in two wells in the same tight formation gas field. The field had been established under statutory procedures as a tight formation field. One well had been certified as producing tight formation gas under the established Federal statutory procedures, and the other had not. Congress provided a tax credit incentive to develop, among other fuels, tight formation gas.
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P owned an interest in two wells in the same tight formation gas field. The field had been established under statutory procedures as a tight formation field. One well had been certified as producing tight formation gas under the established Federal statutory procedures, and the other had not. Congress provided a tax credit incentive to develop, among other fuels, tight formation gas. Sec. 29(c) (2) (A), I.R.C., requires that, as a prerequisite to the credit, "the determination of whether any gas is produced from * * * a tight formation shall be made in accordance with section 503 of the…
1Opinion of the Court
Gerber Judge:
Respondent mailed to True Oil Co. (petitioner), as tax matters partner, notices of final partnership administrative adjustment with respect to Nielson-True Partnership for the taxable years 1991 and 1992. The sole adjustment and issue concerns respondent’s disallowance of section 291 credits in the amounts of $10,170 and $4,394 for 1991 and 1992, respectively.2
FINDINGS OF FACT3
On October 14, 1983, True Oil Co., the tax matters partner, and Nielson Enterprises, Inc., a Delaware corporation, formed the Nielson-True Partnership. The partnership’s principal place of business was…
2Cases cited22 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- United States v. LockeSupreme Court of the United States · 1985
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. BrownSupreme Court of the United States · 1965
- Malat v. RiddellSupreme Court of the United States · 1966
17 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- True Oil Co. v. CommissionerCourt of Appeals for the Tenth Circuit · 1999
- Abdel-Fattah v. CommissionerUnited States Tax Court · 2010
- Green Gas Del. Statutory Trust v. Comm'rUnited States Tax Court · 2016
- S/V Drilling Partners v. CommissionerUnited States Tax Court · 2000
- Finney v. Comm'rUnited States Tax Court · 2009
5 more not listed; retrieve them via the Exa API.