Coping with revenue ruling 83-46: exploring alternatives to the pool of capital theory

Journal Article · Thu Jan 01 04:00:00 EST 1987 · Land Water Law Rev.; (United States)

OSTI ID:6105678

Curnow, R

The Internal Revenue Service is adding to oil and gas industry problems by issuing Revenue Ruling 83-46 because it challenges the long-standing common law doctrine that a contributor of services to the acquisition or development of an oil and gas prospect in return for an economic interest does not realize income until and unless production is attained. The author examines the possibilities for mitigating or circumventing the ruling by using alternative business associations. He concludes that partnerships under the Uniform Partnership Act would be a feasible way to bypass the ruling's tax consequences. He then recommends specific ways to structure the partnership. 59 references.

• OSTI ID: 6105678
• Journal Information: Land Water Law Rev.; (United States), Journal Name: Land Water Law Rev.; (United States) Vol. 22:2; ISSN LWLRD
• 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
294002 -- Energy Planning & Policy-- Petroleum
294003 -- Energy Planning & Policy-- Natural Gas
ADMINISTRATIVE PROCEDURES
CASE LAW
INCOME
INDUSTRY
LAWS
LEGAL ASPECTS
NATIONAL ORGANIZATIONS
ORGANIZING
PETROLEUM INDUSTRY
TAX LAWS
TAXES
US DEPARTMENT OF TREASURY
US IRS
US ORGANIZATIONS