Transfer of proven properties to S corporation does not bar percentage depletion deduction

Journal Article · Sun Sep 01 04:00:00 EDT 1985 · Oil Gas Tax Q.; (United States)

OSTI ID:5157928

The Internal Revenue Service concluded in Private Letter Ruling 8510054 that the transfer of a taxpayer's interest in oil and gas properties to an S corporation of which he is the sole shareholder would not create a transferred proven property under Code Section 613A(c)(9)(A). Therefore, the taxpayer qualifies for the percentage depletion deduction, and this would pass to the taxpayer's heirs along with the stock of the S corporation. The note summarizes the rationale for this ruling.

• OSTI ID: 5157928
• Journal Information: Oil Gas Tax Q.; (United States), Journal Name: Oil Gas Tax Q.; (United States) Vol. 34:1; ISSN OGTQD
• Country of Publication: United States
• Language: English

Related Subjects

02 PETROLEUM
020700* -- Petroleum-- Economics
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29 ENERGY PLANNING, POLICY, AND ECONOMY
294002 -- Energy Planning & Policy-- Petroleum
DEPLETION ALLOWANCES
GEOLOGIC DEPOSITS
INCOME
LAWS
LEGAL ASPECTS
MINERAL RESOURCES
NATIONAL ORGANIZATIONS
PETROLEUM DEPOSITS
RESOURCES
TAX LAWS
TAXES
US DEPARTMENT OF TREASURY
US IRS
US ORGANIZATIONS