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Discussion
Petitioner contends that S/V is entitled to a credit under
section 292 for the 15,483 BOE’s of natural gas it produced from
2 SEC. 29. CREDIT FOR PRODUCING FUEL FROM A
NONCONVENTIONAL SOURCE.
(a) Allowance of credit.
There shall be allowed as a credit against the tax
imposed by this chapter for the taxable year an amount
equal to--
(1) $3, multiplied by
(2) the barrel-of-oil equivalent of qualified
fuels--
(A) sold by the taxpayer to an unrelated person
during the taxable year, and
(B) the production of which is attributable to
the taxpayer.
(b) Limitations and adjustments.
* * * * * * *
(2) Credit and phaseout adjustment based on
inflation.--The $3 amount in subsection (a) and the
$23.50 and $6 amounts in paragraph (1) shall each be
adjusted by multiplying such amount by the inflation
adjustment factor for the calendar year in which the
sale occurs. In the case of gas from a tight
formation, the $3 amount in subsection (a) shall not be
adjusted.
* * * * * * *
(c) Definition of qualified fuels.--For purposes of
this section--
(1) In general. The term “qualified fuels” means--
(continued...)
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Last modified: May 25, 2011