Legal Opinion

Clajon Gas Co., L.P. v. Comm'r

United States Tax Court

Decided October 25, 2002No. 15968-97Published

Partnership C owned and operated natural gas gathering systems to transport gas purchased from natural gas producers. C treated certain pipeline and related components of the gathering systems as natural gas production assets within asset class 13.2 of Rev. Proc. 87-56, 1987-2 C.B. 674, with a 7-year recovery period.

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Partnership C owned and operated natural gas gathering systems to transport gas purchased from natural gas producers. C treated certain pipeline and related components of the gathering systems as natural gas production assets within asset class 13.2 of Rev. Proc. 87-56, 1987-2 C.B. 674, with a 7-year recovery period. Held: Because C's use of its gathering systems determines the proper asset class, and because C was not a "natural gas producer", the components in question are not within asset class 13.2; rather, they are used by C to transport gas and are, therefore, within asset class 46.0,…

1Opinion of the Court

CLAJON GAS CO., L.P., AQUILA GAS PIPELINE CORP., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Clajon Gas Co., L.P. v. Comm'r

No. 15968-97

United States Tax Court

119 T.C. 197; 2002 U.S. Tax Ct. LEXIS 49; 119 T.C. No. 12;

October 25, 2002, Filed

Petitioner must utilize 15-year recovery period to depreciate gathering pipelines.

Partnership C owned and operated natural gas gathering

systems to transport gas purchased from natural gas producers. C

treated certain pipeline and related components of the gathering

systems as natural gas production assets within asset class…

Also in this document: Dissent · Wells; Dissent · Beghe; Dissent · Foley.

2Cases cited10 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Rauenhorst v. Comm'rUnited States Tax Court · 2002
  3. Nicklaus v. Comm'rUnited States Tax Court · 2001
  4. Kenneth L. Phillips v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1988
  5. Coastal Petroleum Refiners, Inc. v. CommissionerUnited States Tax Court · 1990

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