COMMISSIONER OF INTERNAL REVENUE, RESPONDENT, United States Tax Court.https://leagle.com/images/logo.png. Rec. 123673km/47752sqmi. Rec. During the years in issue, petitioners were engaged primarily in exploration for and development, production, refining, and sale of crude oil and natural gas and exploration for, production and mining of other minerals such as sulphur, gold, silver, copper, and coal in the United States and several foreign countries. Copyright 2023 Web Solutions LLC. When we have a project we'll go to Houston, rent a computer and run it through. rice, sugar cane, sweet potatoes, cotton, cattle, dairy products; Saline Company HistoryOil & Natural Gas Extraction. Senator Hollings, a cosponsor of the amendment, added that "not one of those minerals [for which the depletion allowance was retained] has had a four-fold increase in price" as oil and natural gas had in the early 1970's. A number of members criticized the provision for unfairly singling out the oil and gas industry. Section 613A bars percentage depletion for oil and gas wells with two exceptions. This web site and associated pages are not associated with, endorsed by, or sponsored by The Louisiana Land And Exploration Company and has no official or unofficial affiliation with The Louisiana Land And Exploration Company. Louisiana Historical Society and several works Instead, we find that the value of the gas within the terms of the leases is a disputed factual issue to be determined at the hearing on damages. Respondent articulated the applicable principles as follows: Although in the physical sense [carbon dioxide] is a gas, it is not the gas referred to in the term "oil and gas wells" in sections 263(c), 611, 613, and 613A of the Code. In 1955 it reported $13.4 million in profits on sales of $22.4 million. Louisiana Land L. 69-20, sec. WebIn 1946, this original structure was acquired from the Sun Oil Company and transported by barge from Cocodrie, LA to its current location in Paradis. LOUISIANA LAND United States v. American Trucking Association, 310 U.S. 534, 543 (1940). The extent of the damages, if any, suffered by LL & E must be determined in a further proceeding. In the case of oil and gas wells, "gross income from the property" has been interpreted to mean gross income from the sale of the property at the "well-mouth," i.e., before conversion or transportation. The venture's finances faltered and in time there were foreclosures. A number of cities in Louisiana are also home to Jewish communities, The depletable oil quantity is measured in barrels. 4606 (1975). Respondent further argues that Congress would not have used the term "oil and gas wells" as opposed to simply "oil and gas" if it had not intended to limit percentage depletion for all products of oil and gas wells. We offer full engineering support and work with the best and most updated software programs for design SolidWorks and Mastercam. The well effluent is initially treated in a separation system which uses gravity to separate the effluent into brine water, sour crude oil, and a sour gas stream containing natural gas, hydrogen sulfide, and carbon dioxide. In 1988 crude prices fell by more than $3 a barrel and newly named CEO and chairman H. Leyton Steward was forced to take an $81.8 million restructuring charge and a $33.3 million loss. Rec. As if to bear out this description, LL&E's mining operation lost $7.8 million in 1977 and $6.6 million in 1978. The percentage depletion rate for sulphur is 22 percent. Despite dramatic increases in construction and operating costs of Claus sulphur recovery facilities since 1968, the sulphur recovery industry has continued to grow, partly because air-pollution controls mandate the recovery of sulphur from the hydrogen sulfide removed from oil and gas wells even when it may not be economically attractive to do so. The problem in this case arose because Texaco, in an effort to secure a market for natural gas when it was not a particularly valuable commodity, entered into long term sales agreements with Louisiana industrial consumers promising future delivery of gas at what are now below-market prices. and a .03 percent Louisiana Tourism Promotion District sales 7807. those by Henry v. Louisiana Land and Exploration Co WebThe La Land & Exploration Co M 001: API No. In 1984 Phillips was replaced by E. L. Williamson, who worked to sustain profit margins and increase reserves. the more important, as well as the publications of the 1.613-2(b)(4), Income Tax Regs.10 Section 613(b)(1)(A), which provides for percentage depletion at a rate of 22 percent for sulphur, has no limitation based on the source of the sulphur. LAND EXPLORATION CO The well effluent from the Jay Field wells is treated in facilities adjacent to the wells. The term "subject to," in its ordinary sense, means "subordinate to" or "governed or affected by". See: In the Matter of Amoco Production Co., 78 IBLA 93 (1983) (A decision by the Interior Board of Land Appeals with appeal currently pending in the federal district court, western district of La., docket # CV84-0916); Letter opinion by Charles A. Moore, general counsel of Federal Energy Regulatory Commission, addressed to Tipperary Corp., 1982 Federal Program Advisory Service, p. 3, para. At that time, the lodge housed the Louisiana Land and Exploration Companys crew while they constructed a levee around the 3,000 acre property. The other major source of sulphur for commercial use is the Frasch sulphur mining industry. 21 Engel Injection Molding Machines (28 to 300 Ton Capacity), 9 new Rotary Engel Presses (85 Ton Capacity), Rotary and Horizontal Molding, Precision Insert Molding, Full Part Automation, Electric Testing, Hipot Testing, Welding. Although there is scant legislative history on section 613A, the legislative record available leaves little doubt that section 613A was meant to apply only to hydrocarbon fuels. Sulphur dioxide is a gas with an objectionable odor and which can damage both animals and plants. Section 613A was the product of congressional concerns about the nation's increasing dependence on foreign oil and large profits the major integrated oil companies were reaping. 4, 972.) pop(2000e) 4469000; area After processing, the crude oil is classified as sweet rather than sour oil. In the early 1970s, however, its Louisiana reserves began their natural decline. Louisiana Land & Exploration Co. is a corporation lessee based in New Orleans, Louisiana for 11 oil and gas leases8 are authorized and 2 are closed. Click to open an interactive map. Oil and Gas lease entities located at the same street address in New Orleans, Louisiana as Louisiana Land & Exploration Co.. Sec. A literal reading, however, aims the statutory restrictions on percentage depletion at any mineral produced along with oil or gas when the legislative record of section 613A's passage is wholly devoid of mentioning any such important targets. The following June a wholly owned subsidiary of LL&E, the Sun Fire Coal Company, began to develop an underground mine near Hazard, Kentucky. 613(A)(c)(4). Mascrier), Fr. In 1966 he acquired Jacintoport Corporation, an industrial real estate firm with Gulf Coast holdings such as the Houston Ship Channel. petroleum and All the gas involved in this dispute is being used by Texaco to service warranty contracts Texaco entered into with intrastate industrial consumers prior to 1978, when the NGPA was enacted. WebLL E is engaged primarily in exploration for and development of petroleum, natural gas and minerals. 121 Cong. Until 1982, the Frasch mining industry was the dominant source of sulphur in the world. Hydrogen sulfide, alone, or in combination with natural gas is also unsuitable for use as a fuel because the combustion of hydrogen sulfide produces sulphur dioxide, a toxic substance subject to control under Federal pollution standards. Decisions will be entered under Rule 155. Rec. WebDetails for well Sweet Lake Land And Oil Co 001 | API # 17-023-20688 | operated by McMoran Exploration Company in Cameron Parish, LA. Louisiana Land and Exploration Co Respondent thus concludes that we should not allow percentage depletion for sulphur derived from hydrogen sulfide. Business Week called Louisiana Land's record "dismal" and noted that despite spending $1.4 billion over the previous four years Phillips had failed to increase oil and gas reserves. During the House debates, Representative Rhodes noted "that one of the reasons for this bill being brought here with some haste is the fact that we have a shortage of domestic petroleum." This section provides, in pertinent part: Relying on this Section, Texaco has been paying royalties to LL & E based upon the contract prices specified by the warranty contracts which Texaco has been servicing with the LL & E gas. WebLouisiana Land & Exploration Co/The - Company Profile and News - Bloomberg Markets Bloomberg Anywhere Remote Login Manage Products and Account Information Indices Department of Natural Resources | State of Louisiana We find that the use of the term "subject to" in subsection (b), (and again in Section 109) necessarily qualifies the more general language "sold under". In The gas referred to in these sections is hydrocarbon gas. Box 60350 New Orleans, Louisiana 70160 U.S.A. Toll Free: 800-351-1242 Fax: (504) 566-6891 This figure included $181 million for 215 wells; $64 million for leases in Wyoming, the Gulf of Mexico, Australia, Indonesia, Columbia, and the North Sea; and $286 million for construction at Brae Field, platforms in the Gulf of Mexico, and a tertiary recovery project at Jay Field. Rec. tax. Petitioners are calendar year, accrual method taxpayers. Here is a summary of how the competitors of The Louisiana Land and Exploration Company LLC compare to one another: Vastar Resources has the most employees (1,151). Hydrogen sulfide and carbon dioxide are contaminants of natural gas.3 Sour gas cannot be used as fuel; the hydrogen sulfide and carbon dioxide must first be removed.
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