- 43 - D. Petitioner's Use of the Tri-Power NOL's Following the December 1, 1986, dropdown, petitioners applied Tri-Power's NOL's against the income of the dropdown properties. For the years 1986 through 1990, petitioners reported taxable income, before taking into consideration any NOL deductions, and NOL deductions as follows: Year Taxable Income NOL Deductions 1986 $2,015,639 $457,733 1987 4,144,056 4,144,056 1988 8,399,084 8,399,084 1989 10,770,299 10,770,299 1990 12,640,852 12,640,852 During the years in issue, petitioners deducted over $18 million of the Tri-Power NOL's. Petitioner, as a result of the NOL 28(...continued) Year Reserves Acquisition Acquired Name Location Acquired Price 1990 Devon Oil Meeteetse/Wyoming Unknown 436,417 McAdams, Roux & Wyoming Oil & Gas 7,100,000 Associates Morgan Energy West Texas Gas 2,500,000 Partners Murphy Oil New Mexico Oil 2,250,000 Permian Minerals/ West Texas Oil & Gas 9,200,000 Michael Cass 1991 Arch Petroleum West Texas Gas $17,300,000 Michael Cass West Texas Oil 1,500,000 1992 ARCO Wyoming Gas 10,000,000 Phillips Petroleum Wyoming Unknown 635,000 1993 Miscellaneous Various locations Oil & Gas 1,600,000 1994 Anadarko Petroleum Utah, Wyoming Oil & Gas 24,300,000 Ensign Oil & Gas Wyoming Gas 1,850,000 Raydon Exploration Oklahoma Gas 1,825,000 105,390,535Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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