Nielson-True Partnership, True Oil Company, Tax Matters Partner - Page 2

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               related statutes, and FERC regulations, determinations                 
               concerning tight formation gas were required for both                  
               the field in which a well was situated and the                         
               individual well.  R determined that sec. 29, through                   
               reference to NGPA sec. 503, required individual well-                  
               category determinations to qualify for the tax credit.                 
               P contends and R does not deny that but for the lack of                
               a certification under NGPA sec. 503, the well in                       
               question would meet the qualifications for tight                       
               formation gas.  P contends that meeting the                            
               qualification by definition (in substance) should                      
               suffice and that actual certification is unnecessary.                  
                    Held:  Sec. 29, I.R.C., when read in conjunction                  
               with the provisions of NGPA sec. 503 and related                       
               materials, requires an individual well tight formation                 
               gas determination under the procedures of NGPA sec. 503                
               as prerequisite to tax credit eligibility.                             

               Douglas A. Pluss and Ronald M. Morris, for petitioner.                 
               Richard D. D'Estrada, for respondent.                                  

               GERBER, Judge:  Respondent mailed to True Oil Co.                      
          (petitioner), as tax matters partner, notices of final                      
          partnership administrative adjustment with respect to Nielson-              
          True Partnership for the taxable years 1991 and 1992.  The sole             
          adjustment and issue concerns respondent's disallowance of                  
          section 291 credits in the amounts of $10,170 and $4,394 for 1991           
          and 1992, respectively.2                                                    

               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code in effect for the taxable years at issue,             
          and Rule references are to this Court's Rules of Practice and               
               2 These cases were consolidated for purposes of trial,                 
          briefing, and opinion.                                                      

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