- 14 -
formation, for a total of 32,410 BOE’s.3
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
Reviewed by the Court.
COHEN, CHABOT, PARR, WELLS, RUWE, WHALEN, BEGHE, CHIECHI,
LARO, GALE, THORNTON, and MARVEL, JJ., agree with this majority
opinion.
3 In computing its credit for the 16,927 BOE’s of gas
produced from both Devonian shale and a tight formation,
petitioner used the 1995, rather than the 1994, inflation
adjustment factor. See sec. 29(d)(2); I.R.S. Notice 96-29, 1996-
1 C.B. 377; I.R.S. Notice 95-26, 1995-1 C.B. 305. Accordingly,
petitioner overstated its 1994 credit for such gas by $639.
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