- 2 - Dom W. Greco, for petitioner. Michael A. Yost, Jr. and Edward F. Peduzzi, Jr., for respondent. OPINION COLVIN, Judge: On August 3, 1998, respondent issued two notices of final partnership administrative adjustment to S/V Drilling Partners (S/V), a partnership, in which respondent determined adjustments to S/V’s partnership returns for the tax years ending December 31, 1993 and 1994. On August 18, 1998, Snyder Armclar Gas Co. (Snyder), S/V’s tax matters partner, petitioned the Court to redetermine respondent’s adjustments to partnership items. In 1993 and 1994, S/V sold 32,410 barrels of oil equivalent (BOE’s)1 of natural gas produced from nonconventional sources, consisting of 15,483 BOE’s of gas produced from a tight formation that was not Devonian shale and 16,927 BOE’s of gas produced from both a tight formation and Devonian shale. The issue for decision is the amount of S/V’s section 29 credit. We hold that S/V is allowed a section 29 credit equal to (1) 15,483 times $3, and (2) 16,927 times $3 indexed as provided in the first sentence of section 29(b)(2). 1 A barrel of oil contains about 5.8 million British thermal units (Btu’s).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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