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a tight formation that was not Devonian shale and a double credit
for the 16,927 BOE’s it produced from a tight formation that was
also Devonian shale. Thus, petitioner, in effect, contends that
S/V produced 49,337 BOE’s (i.e., 15,483 plus (2 X 16,927)) of gas
qualifying for the credit under section 29.
Respondent contends that S/V is entitled to a credit for
only 16,927 BOE’s of gas. Respondent contends that S/V is
entitled only to the larger of:
1. A $3 per barrel credit for the 32,410 BOE’s of natural
gas S/V produced, or
2. A credit for the 16,927 BOE’s of natural gas S/V
2(...continued)
(A) oil produced from shale and tar sands,
(B) gas produced from--
(i) geopressured brine, Devonian shale, coal
seams, or a tight formation, or
(ii) biomass, and
(C) liquid, gaseous, or solid synthetic fuels
produced from coal (including lignite), including such
fuels when used as feedstocks.
* * * * * * *
(d) Other definitions and special rules.
* * * * * * *
(5) Barrel-of-oil equivalent.--The term “barrel-
of-oil equivalent” with respect to any fuel means that
amount of such fuel which has a Btu content of 5.8
million * * *.
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Last modified: May 25, 2011