- 20 -20
We are persuaded that Congress intended to couple the
eligibility for the section 29 credit with the obtaining of well-
category determinations under NGPA section 503. In particular,
the legislative history of the Decontrol Act indicates that the
repeal of FERC's determination review providing for incentive
pricing in NGPA section 503 was not intended to affect the
availability of the nonconventional fuels tax credit. S. Rept.
101-39, supra at 9.12
Equally significant, the aforementioned congressional action
illustrates an understanding that section 29 was linked with a
procedural determination under NGPA section 503. Petitioner's
perspective is that the FERC determination process was left in
place to continue the process of defining tight formation gas.
Even if that was the basic reason for extension, the section 29
statutory language plainly requires a "determination" under NGPA
section 503.
12 See also Staff of Joint Comm. on Taxation, Technical
Explanation of the Tax Simplification Act of 1993, at 204 (J.
Comm. Print 1993). (The Tax Simplification Act of 1993 was not
enacted.) That report contains the statement that
In order to ensure that qualifying gas production
from such wells in fact will receive the credit, it is
believed necessary to continue the well and formation
determination process for periods after * * * [the
Commission] discontinues its role in this process. [Id.
at 205; emphasis added.]
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