- 2 -
June 30, 1992 11,493,555 911,504
June 30, 1993 10,717,851 1,401,649
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
After concessions, the issues for decision are:
1. Whether sections 3821 and 383 bar the use of Continental
Drilling Co.'s (CDC) net operating loss (NOL) and investment tax
credit (ITC) carryforwards by Samson Investment Co. and its
subsidiaries (Samson, the Samson group, or petitioner) in
petitioner's taxable years ending June 30, 1990 through 1993;
2. whether drilling rigs and related equipment owned by CDC
and Eason Drilling Co. (Eason) were subject to depreciation under
section 167 in petitioner's taxable years ending June 30, 1990
through 1993; and
3. whether petitioner is liable for penalties for
substantial understatements of its tax liability for the taxable
years ending June 30, 1990 through 1993.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
1 References to secs. 382 and 383 and the regulations
thereunder are to the Internal Revenue Code and applicable
regulations in effect on Dec. 31, 1986.
2 Respondent has determined penalties only with respect to
the sec. 382 and sec. 383 issues.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011