S/V Drilling Partners, Snyder Armclar Gas Company, Tax Matters Partners v. Commissioner

114 T.C. No. 4

UNITED STATES TAX COURT S/V DRILLING PARTNERS, SNYDER ARMCLAR GAS COMPANY, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14163-98. Filed February 23, 2000. Sec. 29, I.R.C., provides a credit for fuel produced from nonconventional sources, including gas produced from geopressurized brine, Devonian shale, coal seams, or a tight formation. In 1993 and 1994, S/V, a partnership, sold 32,410 barrels of oil equivalent (BOE’s) of natural gas produced from nonconventional sources described under sec. 29, I.R.C. S/V sold 15,483 BOE’s of gas…