- 8 -
equivalent (before any indexing for inflation). That report
states in pertinent part that the credit:
would be equal to $3 for the production of an amount of
energy equivalent to that contained in a barrel of
crude oil, and all energy equivalent measurements would
be made on the basis of Btu content. Therefore, a $3
credit would be allowed for the production of 5.8
million Btu’s of energy.
* * * * * * *
The credit would be $3 for the production of 5.8
million Btu’s * * * .
S. Rept. 96-394, at 87, 89 (1979), 1980-3 C.B. 131, 205, 207.
Similarly, the conference report states in pertinent part
that the “credit is $3 for the production of each unit of 5.8
million Btus of energy, the equivalent of one barrel of oil”. H.
Conf. Rept. 96-817, at 140 (1980), 1980-3 C.B. 245, 300.
The Senate bill also provided a formula to determine the
entitlement to the credit for taxpayers with a fractional
interest in the property:
Production from a property shall be attributed to the
taxpayer for the taxable year in an amount which bears
the same ratio to the total sales during such year of
qualified fuels from such property as the amount of the
taxpayer’s gross income from such property for such
year from such sales bears to the aggregate gross
income from such property for such year from such
sales. [Crude Oil Windfall Profit Tax Act of 1979,
H.R. 3919, sec. 251, 96th Cong., proposing new I.R.C.
sec. 44D(3)(3)(A).]
Thus, the committee reports, as well as section 29, show
that Congress intended the credit to be based on the barrel of
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