- 6 - A gas processing contract is similar, except that Clajon and the producer share revenues from Clajon’s sale of extracted NGLs and residue gas. Under a gas transportation contract, Clajon charges its customers a fee to move gas through one of the Texas gathering systems. Depreciation Adjustments in Dispute Respondent’s adjustments to “pipeline depreciation” consist of separate adjustments with respect to “pipelines”, “compressor stations” and “meter runs”. Clajon depreciated those assets using a 7-year recovery period. Respondent determined that Clajon should have used a 15-year recovery period. We shall generally refer to the foregoing elements of Clajon’s gathering system, collectively and without distinction, as “gathering pipelines”. OPINION I. Introduction This case involves a dispute as to the length (in years) of the recovery period that Clajon must use in calculating its annual depreciation deductions for the gathering pipelines. On similar facts, we decided in the Commissioner’s favor in Duke Energy Natural Gas Corp. v. Commissioner, 109 T.C. 416 (1997), revd. 172 F.3d 1255 (10th Cir. 1999). Petitioner urges us not to follow our decision in Duke Energy and to adopt the reasoning ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011