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U.S. Department of Energy
Office of Scientific and Technical Information

Revenue Ruling 77-176 revisited

Journal Article · · Oil Gas Tax Q.; (United States)
OSTI ID:5189347

Farm-out arrangements are used in the oil and gas industry to share operating interests in exchange for contributions to exploring and developing a property. Originally nontaxable, new farm-out transaction rulings define separate properties for each taxpayer in the transaction on the grounds that the mineral interests of the taxpayers are dissimilar. The impact of this ruling is detrimental to carved-out drill sites. Several plans are suggested for testing this ruling in the courts. Although legal action, such as an injunction, can be counterproductive, it may be the only solution. (DCK)

OSTI ID:
5189347
Journal Information:
Oil Gas Tax Q.; (United States), Journal Name: Oil Gas Tax Q.; (United States) Vol. 28:2; ISSN OGTQD
Country of Publication:
United States
Language:
English