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  • Gates Rubber Company, and Subsidiaries v. Commissioner of Internal Revenue, 694 F.2d 648, 10th Cir. (1982)

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    The document is a court case from the United States Court of Appeals for the Tenth Circuit regarding whether costs incurred from drilling offshore exploratory oil and gas wells from mobile rigs can be deducted in the year incurred under Section 263(c) of the Internal Revenue Code and Treasury Regulation 1.612-4(a). The Tax Court previously ruled in favor of the taxpayer/appellee. The Third Circuit also previously ruled in favor of the taxpayer in an identical case. The Tenth Circuit affirms the Tax Court's ruling in favor of the taxpayer, agreeing with the Third Circuit's prior identical ruling.

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    Filed: 1982-12-03 Precedential Status: Precedential Citations: 694 F.2d 648 Docket: 81-1523

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    The document is a court case from the United States Court of Appeals for the Tenth Circuit regarding whether costs incurred from drilling offshore exploratory oil and gas wells from mobile rigs can be deducted in the year incurred under Section 263(c) of the Internal Revenue Code and Treasury Regulation 1.612-4(a). The Tax Court previously ruled in favor of the taxpayer/appellee. The Third Circuit also previously ruled in favor of the taxpayer in an identical case. The Tenth Circuit affirms the Tax Court's ruling in favor of the taxpayer, agreeing with the Third Circuit's prior identical ruling.

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    7 views2 pages

    Gates Rubber Company, and Subsidiaries v. Commissioner of Internal Revenue, 694 F.2d 648, 10th Cir. (1982)

    Uploaded by

    Scribd Government Docs
    The document is a court case from the United States Court of Appeals for the Tenth Circuit regarding whether costs incurred from drilling offshore exploratory oil and gas wells from mobile rigs can be deducted in the year incurred under Section 263(c) of the Internal Revenue Code and Treasury Regulation 1.612-4(a). The Tax Court previously ruled in favor of the taxpayer/appellee. The Third Circuit also previously ruled in favor of the taxpayer in an identical case. The Tenth Circuit affirms the Tax Court's ruling in favor of the taxpayer, agreeing with the Third Circuit's prior identical ruling.

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    of 2

    694 F.

    2d 648
    82-2 USTC P 9702

    GATES RUBBER COMPANY, AND SUBSIDIARIES,


    Appellee,
    v.
    COMMISSIONER OF INTERNAL REVENUE, Appellant.
    No. 81-1523.

    United States Court of Appeals,


    Tenth Circuit.
    Dec. 3, 1982.

    George L. Hastings, Jr., Tax Div., Dept. of Justice, Washington, D.C.


    (with John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup and Gary
    R. Allen, Tax Div., Dept. of Justice, Washington, D.C., on the brief), for
    appellant.
    Buford P. Berry, Dallas, Tex. (with J.W. Bullion and Emily A. Parker,
    Dallas, Tex., on the brief), of Thompson & Knight, Dallas, Tex., for
    appellee.
    Before BARRETT, McKAY and LOGAN, Circuit Judges.
    PER CURIAM.

    In this appeal we are asked to decide whether the costs of drilling offshore
    exploratory oil and gas wells from mobile rigs are deductible in the year in
    which they are incurred as "intangible drilling and development costs" under 26
    U.S.C. Sec. 263(c) and Treas.Reg. Sec. 1.612-4(a) ("the IDC option"). The Tax
    Court, 74 T.C. 1456, ruled in favor of the taxpayer and against the
    Commissioner.

    All parties agree that the issue in this case is identical with the prior
    consideration of this issue by the Third Circuit in Sun Co. v. Commissioner,
    677 F.2d 294 (3rd Cir.1982). The Third Circuit held for the taxpayer. We agree
    with the Third Circuit.

    3
    AFFIRMED.

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