Wednesday, July 9, 1997. Petitioners extracted four categories of products from the Jay Field wells: liquid hydrocarbons, gaseous hydrocarbons, nonhydrocarbon gases, and nonhydrocarbon liquids.2. Respondent thus concludes that if hydrogen sulfide, from which sulphur is derived, is produced from an oil or gas well, it is depletable, if at all, only under section 613A. 121 Cong. Our conclusion is buttressed by the fact that all the existing authority on this point, although persuasive rather than authoritative, has interpreted the phrase "subject to" in Section 105 as requiring that a source of gas be described in a contract in order to trigger the Section's application. Texaco's argument is based upon isolating the term "sold under" in subsection (a) of Section 105, rather than reading the Section as a whole to determine its meaning. The goal of the legislation was to continue to provide the tax incentive of percentage depletion to small producers and royalty owners to encourage exploration for and exploitation of domestic oil and gas reserves while eliminating such tax incentives for the major integrated oil companies. After considering the language, structure and legislative record of the passage of section 613A, we do not believe that section 613A was intended to limit sulphur depletion pursuant to section 613(b)(1). Rule 91(e), Tax Court Rules of Practice and Procedure. fertile delta lands; further inland are plains and low rolling United States v. American Trucking Association, 310 U.S. 534, 543 (1940). Senator Hollings, a cosponsor of the amendment, added that "not one of those minerals [for which the depletion allowance was retained] has had a four-fold increase in price" as oil and natural gas had in the early 1970's. LLEC began attempting to mark that boundary, first with a ditch and later by removing the Liners stakes at the edges of their claimed land. Oil and Gas Indian Communitization Agreement, Oil and Gas Simultaneous Lease Drawing (SIMO) on Public Land, Oil and Gas Simultaneous Lease Drawing (SIMO) on Acquired Land, Oil and Gas Non-Competitive Lease on Acquired Land, Louisiana Land & Exploration Co. is listed with 11 total leases. Sec. Finally, respondent's interpretation of section 613A conflicts with normal usage of the term "natural gas" as meaning fuel. Of the company's 225 million barrels of oil equivalent reserves, nearly 60 percent are garnered from domestic sources. Foreign reserves are located in the U.K. and Dutch sectors of the North Sea, Canada, and Columbia. LL&E traces its roots to the 19th century, when midwestern businessman Edward Wisner moved to Louisiana for his health. In February 1943, President E. B. Tracy signed a contract with Duval Texas Sulfur Co. that gave that company sulfur exploration, development, and production rights on LL&E's land and leased interests in Louisiana's Terebonne Parish. See United States v. 3,788.16 Acres of Land, 439 F.2d 291, 294 (8th Cir. Louisiana Historical Society and several works WebContinuing the marriages among energy companies, Burlington Resources Inc. agreed to acquire Louisiana Land & Exploration Co. for about $2.44 billion in stock. Specifically, subparagraph (C) does not state "minerals from oil and gas wells.". For example, we don't hesitate to use consultants. For the purposes of this subsection, minerals (other than sodium chloride) extracted from brines pumped from a saline perennial lake within the United States shall not be considered minerals from an inexhaustible source. 7295. Escalating energy prices and the Arab oil embargo awakened the public to the Nation's growing reliance on foreign energy resources. 613A(c)(4). Click the citation to see the full text of the cited case. The exemptions from the general rule of section 613A(a) denying percentage depletion for oil and gas wells, however, function only when applied to hydrocarbon fuels. Bayou, a National Wild and Scenic River in northern WebThe Louisiana Land and Exploration Company 909 Poydras Street P.O. Login | Register; Home; Operators; Leases; Wells; Permits; Pricing; Search; Map; Sweet Lake Land And Oil Co 001: API No. With no more than 4.4 years of proven reserves on hand in 1980, Phillips needed to find new reserves at a reasonable cost if he was to insure the company's continued profitability. LL&E traces its roots to the 19th century, when midwestern businessman Edward Wisner moved to Louisiana for his health. the first historian of Louisiana with his. The acid gas next is separated from the amine solution and passed into a multistage Claus sulphur recovery system, where hydrogen sulfide is converted into molten elemental sulphur by controlled combustion with air. These geospatial data and related maps or graphics are not legal documents and are not intended to be used as such. Rec. v. 121 Cong. ", But while Graham focused on controlling costs, he, like other CEOs of that era, also sought profits in new businesses. Respondent articulated the applicable principles as follows: Although in the physical sense [carbon dioxide] is a gas, it is not the gas referred to in the term "oil and gas wells" in sections 263(c), 611, 613, and 613A of the Code. Respondent, however, has entered into a stipulation of facts with petitioner pursuant to which he agreed as follows: Petitioner[s] claimed percentage depletion deductions on sulphur in [their] tax returns in the following amounts: If Petitioner[s'] sulphur production is subject to depletion under section 613(b) of the Code, Petitioner[s] [are] entitled to the sulphur percentage depletion deductions listed above. 204(c)(2), 44 Stat. Respondent's view may be a valid literal reading of section 613A(e)(2). 121 Cong. Raising this argument for the first time in his post-trial brief, respondent would argue a case that petitioners were unable to develop for trial and would, consequently, prejudice petitioners' case. Sulphur is not depletable under section 613(b)(7) because depletion for sulphur is expressly provided for in subsection (b)(1). Section 613(b)(7) is a catch-all provision for minerals not mentioned elsewhere in the subsection. 6903 (1975) (statement of Senator Bentsen). Decisions will be entered under Rule 155. The same year he paid $486 million for Inexco Oil Co., an oil company with reserves that included 9.9 million barrels of liquids and 392.7 million cubic feet of domestic natural gas reserves. LL&E enjoyed a good exploration year in 1990. All Rights Reserved posthumous and further expanded edition in The district court's decision is a proper partial summary judgment under Louisiana Code of Civil Procedure article 966(C), which provides that summary judgment "may be rendered on the issue of liability alone although there is a genuine issue as to the amount of damages." 8128, and Senator Curtis added, "Our first objective should be the production of more gas and oil." Visit DandB.com to locate more business profiles. It continued, however, with its policy of contracting other firms to perform seismic surveys and other exploration and development tasks. As on previous occasions, LL&E's involvement was a financial one. LL&E is a Maryland corporation having its principal office at New Orleans, Louisiana. We offer full engineering support and work with the best and most updated software programs for design SolidWorks and Mastercam. Through its subsidiary, The Louisiana Land and Exploration Company LLC (LL&E), ConocoPhillips is the largest private wetlands owner in Louisiana. In the Senate, Senator Dole remarked that "The 2,000 barrel * * * exemption from the depletion allowance repeal is vitally important to maintaining a high level of energy exploration and production," 121 Cong. This type of contract differs from the so-called "dedication" contract, whereby the producer contracts with a customer agreeing to furnish all the gas produced from specified reserves, thus "dedicating" those reserves to the particular customer. Congress responded to this public outcry by repealing the percentage depletion allowance as applied to the major integrated oil companies.". oil and natural gas were discovered; capital, Baton Rouge; other (a) GENERAL RULE.Except as otherwise provided in this section, the allowance for depletion under section 611 with respect to any oil or gas well shall be computed without regard to section 613. The oil stabilization system also reduces the vapor pressure of the crude oil to a low enough level that it can be stored and transported in atmospheric tanks and tank trucks. See Rev. Continuing the marriages among energy companies, Burlington Resources Inc. agreed to acquire Louisiana Land & Exploration Co. for about $2.44 billion in stock. The companies' officials say the transaction will create one of the largest independent oil and natural-gas concerns in the country in terms of reserves and production. Lease No. To make matters worse, copper revenues declined and precious metals margins shrank. Docket Nos. THE LOUISIANA LAND AND EXPLORATION COMPANY DONATES THE ISLES DERNIERES CHAIN OF ISLANDS TO THE STATE OF LOUISIANA. LL & E, which leases certain lands to Texaco for the production of gas, brought suit against Texaco claiming Texaco had failed to pay proper royalties under the leases. The term "subject to," in its ordinary sense, means "subordinate to" or "governed or affected by". Sec. At Furnel, Inc. our goal is to find new ways to support our customers with innovative design concepts thus reducing costs and increasing product quality and reliability. Tenneco Exploration, Ltd. v. Federal Energy Regulatory Commission, wherein the federal Fifth Circuit read NGPA Section 104 in para materia with Section 109 to determine the applicability of Section 109 to gas that had not been committed or dedicated to interstate commerce within the meaning of the NGPA.). Foster, announced that The Louisiana Land and Exploration Company is donating to the State of Louisiana the surface rights to its land holdings in the Isles Dernieres chain of barrier The Louisiana Land and Exploration Company LLC operates as a subsidiary of ConocoPhillips. ), among them As the largest owner of environmentally sensitive wetlands in the continental United States, LL&E had long been careful to protect its investment. Leagle.com reserves the right to edit or remove comments but is under no obligation to do so, or to explain individual moderation decisions. Natchitoches, Cane River Creole National Historical Park in When brought to the surface, all of the items in the wells are physically mixed. Sec. WebThe company changed its name to St. Mary Land & Exploration Company on October 13, 1992 and then shortly thereafter, went public on the NASDAQ exchange with the ticker symbol MARY. Mascrier), Fr. It was solely Texaco's choice to meet its obligations to these customers with LL & E's gas. LL&E continued to do quite well in the late 1960s and early 1970s, reporting income of $51.9 million on 1970 sales of $114 million. In a vessel called a contactor, an amine solution such as sulfinal is added to the sour gas. Epps. Graham worked hard to keep expenses down. (A salt dome is a raised central area of salt or rock, around which beds of sedimentary rock dip in all directions. In 1943, for instance, LL&E employed only 24 people, yet earned $1.8 million on sales of $3.4 million. A number of cities in Louisiana are also home to Jewish communities, 7770-7773, 7813 (1975). Management trumped Caspary, however, when it pledged to spin off to stockholders a tax-sheltered royalty trust holding oil and gas properties that generated $30 million a year. And profit sharing on top of the royalty was unheard of.". around New Orleans; special population groups of Creoles (French 121 Cong. During the 1950s, CEO Robert M. Youngs began investing in working interest wells. Saline Nevertheless, the company budgeted $200 million for capital and exploration and continued to drill in the Gulf of Mexico, Madden Field in Wyoming, the gas-rich Anadarko Basin of Western Oklahoma, the North Sea, southeastern Alberta, and Columbia, where it was garnering positive results from a drilling program begun in 1978. Moreover, respondent's reading of section 613A could discourage oil and gas production by independent producers and royalty owners, which would be contrary to congressional intent.
