Transfers of proven oil and gas properties from individuals to controlled corporations
Code Section 613A(c) (10) sets forth an exception, for transfers by individuals to their controlled corporations, to the general rule of section 613A(c)(9) denying percentage depletion to transferees of proven oil and gas properties. The proposed regulations attempt to provide guidelines to help taxpayers comply, and, although these regulations are not all-inclusive, they should be helpful to taxpayers who must rely on these provisions to prevent the loss of deductions for percentage depletion. Because of some apparent ambiguities in this area of the Internal Revenue Code and Treasury's inability to flesh out these ambiguities in its proposed regulations, affected taxpayers should be cautious. 2 tables.
- Research Organization:
- Clemson Univ., SC
- OSTI ID:
- 6166227
- Journal Information:
- Oil Gas Tax Q.; (United States), Journal Name: Oil Gas Tax Q.; (United States) Vol. 34:2; ISSN OGTQD
- Country of Publication:
- United States
- Language:
- English
Similar Records
Percentage depletion available to partners following the contribution or distribution of proven properties
Reich, A. E. et al. vs Commissioner of Internal Revenue and G. D. Rowan et al. vs Commissioner of Internal Revenue. U. S. Court of Appeals, Ninth Circuit. January 21, 1972. [Judicial interpretation of IRS tax regulations relative to depletion allowance for geothermal well drilling and development; 26 CFR 1. 263(c), 1. 611(a), and 1. 613(b)]
Related Subjects
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
DEPLETION ALLOWANCES
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