Relationship of the percentage depletion allowance and the dividends received deduction: a disagreement with the tax court

Journal Article · Thu Sep 01 04:00:00 EDT 1983 · Oil Gas Tax Q.; (United States)

OSTI ID:5290083

Orbach, K N

Arguments against the Tax Court's holding in Lastarmo, Inc. v. Commissioner review the equations for solving the percentage depletion deduction (PD) and dividends received deduction (DRD) interrelationship to determine whether a corporate taxpayer has had a net operating loss (NOL). The Tax Court sought to fill a perceived gap in Internal Revenue Service statutory framework which the author considers invalid because of the calculations used to prove NOL. His calculations show that none existed. 48 references. (DCK)

• Research Organization: Louisiana State Univ., Baton Rouge
• OSTI ID: 5290083
• Journal Information: Oil Gas Tax Q.; (United States), Journal Name: Oil Gas Tax Q.; (United States) Vol. 32:1; ISSN OGTQD
• Country of Publication: United States
• Language: English

Related Subjects

02 PETROLEUM
021000* -- Petroleum-- Legislation & Regulations
03 NATURAL GAS
031000 -- Natural Gas-- Legislation & Regulations
29 ENERGY PLANNING, POLICY, AND ECONOMY
290200 -- Energy Planning & Policy-- Economics & Sociology
294002 -- Energy Planning & Policy-- Petroleum
294003 -- Energy Planning & Policy-- Natural Gas
CALCULATION METHODS
CASE LAW
COST
DEPLETION ALLOWANCES
INDUSTRY
LAWS
LEGAL ASPECTS
OPERATING COST
PETROLEUM INDUSTRY
TAX LAWS
TAXES