- 3 - Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. Background The parties submitted this case fully stipulated under Rule 122. S/V’s principal place of business was Kittanning, Pennsylvania, when the petition was filed. A. S/V’s Natural Gas Production From a Tight Formation and Devonian Shale In 1992, S/V, a partnership composed of Snyder and Victory Energy Corp. (Victory), drilled eight natural gas wells in Armstrong and Indiana Counties, Pennsylvania. In December of that year, Victory filed with the Pennsylvania Department of Environmental Resources (DER) two classification requests for each well, seeking determinations that these wells produced natural gas from Devonian shale and from a tight formation. The requests were made under section 503 of the Natural Gas Policy Act of 1978 (NGPA), Pub. L. 95-621, 92 Stat. 3350, 15 U.S.C. sec. 3413 (1988) (repealed January 1, 1993, by the Natural Gas Wellhead Decontrol Act of 1989, Pub. L. 101-60, sec. 3(b)(5), 103 Stat. 157, 159). DER approved Victory’s requests and determined that the wells were producing natural gas from rock formations that qualified as both Devonian shale and a tight formation. The Federal Energy Regulatory Commission (FERC) approved DER’s determinations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011