Shell Oil Co. v. Comm'r of Internal Revenue

7 Citing cases

  1. CGG Ams., Inc. v. Comm'r of Internal Revenue

    147 T.C. No. 2 (U.S.T.C. Jul. 21, 2016)   Cited 19 times

    These cases are Standard Oil Co. v. Commissioner, 68 T.C. 325, 327 (1977), aff'd sub nom. Sun Co. & Subs. v. Commissioner, 677 F.2d 294 (3d Cir. 1982), Gates Rubber Co. & Subs. v. Commissioner, 74 T.C. 1456, 1459 (1980), aff'd, 694 F.2d 648 (10th Cir. 1982), and Shell Oil Co. v. Commissioner, 89 T.C. 371, 399 (1987), supplemented by 90 T.C. 747 (1988), rev'd in part and remanded in part, 952 F.2d 885 (5th Cir. 1992). In Standard Oil Co. v. Commissioner, 68 T.C. at 327, the taxpayer (and/or its subsidiaries) incurred expenses to "obtain geological and geophysical information (G&G) relating to the subsurface configurations underlying the offshore waters".

  2. Shell Oil Co. v. Comm'r of Internal Revenue

    90 T.C. 48 (U.S.T.C. 1988)   Cited 3 times

    GOFFE In Shell Oil Co. v. Commissioner, 89 T.C. 371 (1987), the Commissioner determined deficiencies in petitioner's windfall profit tax for the taxable quarters ended March 31, 1980, June 30, 1980, September 30, 1980, and December 31, 1980, and alternatively, for the taxable year 1980. The parties disagreed over the attribution and allocation of certain expenses for the calculation of the taxable income from petitioner's oil and gas properties for purposes of the windfall profit tax net income limitation.

  3. Union Texas Int'l Corp. v. Comm'r of Internal Revenue

    110 T.C. 321 (U.S.T.C. 1998)   Cited 3 times

    Petitioners, in reliance on Shell Oil Co. v. Commissioner, 89 T.C. 371, 1987 WL 45151 (1987), supplemented by 90 T.C. 747, 1988 WL 34874 (1988), revd. in part and remanded in part 952 F.2d 885 (5th Cir.1992), argue that they are entitled to claim the benefit of changes in law, new facts, or any other item that might affect the taxpayer's liability. See secs. 6511, 6512(b); see also Stone v. White, 301 U.S. 532, 534–535, 57 S.Ct. 851, 81 L.Ed. 1265 (1937); Bull v. United States, 295 U.S. 247, 260–262, 55 S.Ct. 695, 79 L.Ed. 1421 (1935).

  4. Miles Prod. Co. v. Comm'r of Internal Revenue

    96 T.C. 595 (U.S.T.C. 1991)   Cited 1 times
    Holding valid a notice referencing calendar year rather than fiscal year

    This is known as the NIL and requires computation of the net income attributable to each barrel of oil for each property. Shell Oil Co. v. Commissioner, 89 T.C. 371, 383 (1987), supplemented by 90 T.C. 747 (1988). If the withholding of windfall profit tax is inadequate, the producer must file a return for a calendar year.

  5. Transco Exploration Co. v. Comm'r of Internal Revenue

    95 T.C. 373 (U.S.T.C. 1990)

    Section 4986(a) imposes the tax upon the ‘windfall profit‘ calculated for each taxable period. See generally Shell Oil Co. v. Commissioner, 89 T.C. 371 (1987); Page v. Commissioner, 86 T.C. 1 (1986). ‘Windfall profit‘ is calculated under section 4988(a) and is the excess of the removal price of each barrel of crude oil over the sum of (1) the adjusted base price of such barrel, and (2) the amount of the severance tax adjustment with respect to such barrel.

  6. Natomas North America, Inc. v. Comm'r of Internal Revenue

    90 T.C. 710 (U.S.T.C. 1988)

    The Crude Oil Windfall Profit Tax Act of 1980, Pub. L. 96-223, 94 Stat. 229, imposes a temporary excise, or severance, tax on certain crude oil produced in the United States. See sec. 4986; Shell Oil Company v. Commissioner, 89 T.C. 371 (1987). The tax is computed under section 4987 as a percentage of the windfall profit defined by section 4988(a).

  7. Natomas North America v. Commr. of Internal Revenue

    90 T.C. 710 (U.S.T.C. 1988)

    The Crude Oil Windfall Profit Tax Act of 1980, Pub.L. 96-223, 94 Stat. 229, imposes a temporary excise, or severance, tax on certain crude oil produced in the United States. See sec. 4986; Shell Oil Co. v. Commissioner, 89 T.C. 371 (1987). The tax is computed under section 4987 as a percentage of the windfall profit defined by section 4988 (a).