Nielson-True Partnership, True Oil Company, Tax Matters Partner - Page 15

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             not comport with the overall statutory design for obtaining the                                      
             benefit of the tax credit.                                                                           
                    Petitioner relied heavily on the legislative history to                                       
             present its position.  Petitioner contends that the legislative                                      
             history reveals Congress' intent that section 29 required that a                                     
             well meet the definition of a tight formation as utilized by FERC                                    
             in the NGPA section 503 administrative process.  Although the                                        
             legislative history does contain some references to possibilities                                    
             for employing definitions established by FERC, those references                                      
             do not provide a basis for holding that the term "determination"                                     
             should be interpreted differently from its usual and established                                     
             meaning.  Our examination of petitioner's argument leads us to                                       
             the same conclusion whether or not we consider the statute to be                                     
             ambiguous.  In addition, we may seek out any reliable evidence as                                    
             to the legislative purpose even where the statute is clear.                                          
             United States v. American Trucking Associations, Inc., 310 U.S.                                      
             at 543-544; Centel Communications Co. v. Commissioner, 92 T.C.                                       
             612, 628 (1989), affd. 920 F.2d 1335 (7th Cir. 1990).                                                
                    Congress enacted the NGPA in response to a generally growing                                  
             demand for natural gas and rising prices for energy in the late                                      
             seventies and early eighties.  Williams Natural Gas Co. v. FERC,                                     
             872 F.2d at 440; ANR Pipeline Co. v. FERC, 870 F.2d 717, 719                                         
             (D.C. Cir. 1989).  Producers of gas from tight formations could                                      
             qualify for incentive gas prices higher than the ceiling.  These                                     
             incentive prices were valuable when uncontrolled gas prices were                                     

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