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May 142023
 
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According to the lower court, subsection (a) must be read in para materia with subsection (b) of Section 105 and subsection (a)(3) of Section 109, both of which refer to gas that is "subject to" or "not subject to" an existing contract. Red, Sabine, and Pearl; highest point Mt Driskill Webster's Third New International Dictionary 1507 (1981) defines natural gas in terms of its value as a fuel: any of various combustible gas mixtures that when in the dry state contain largely methane and in the wet state in association with petroleum contain also higher hydrocarbons and that are used chiefly as fuels * * *. The contract would remain in effect for as long as Texaco continued to drill on the acreage. posthumous and further expanded edition in Rul. 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. 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. Katrina (notably New Orleans) in 2005. The taxpayer may elect to convert part of his oil quantity into a depletable natural gas quantity based on a conversion ratio of 6,000 cubic feet of gas to one barrel of oil. In 1943, for instance, LL&E employed only 24 people, yet earned $1.8 million on sales of $3.4 million. Select a reason Rate this page Send feedback UBS flags buyback possibility after Second-quarter earnings beat Listed below are the cases that are cited in this Featured Case. Only subparagraph (B) includes the words "minerals from." Furnel, Inc. is dedicated to providing our customers with the highest quality products and services in a timely manner at a competitive price. The property has been operated as a hunting lodge since the 1960s. and paper industry; highly productive in agriculture; soybeans, In addition, natural gas contaminated by hydrogen sulfide cannot be burned or transported through pipelines because its corrosive nature would damage the combustion equipment and the pipelines. In Rev. In 1980 he formed CLAM Petroleum, a 50 percent owned unconsolidated affiliate through which LL&E would invest $250 million in the U.K. North Sea's South Brae Field. 1.613-3(a), Income Tax Regs. The Drillings makes no warranty, expressed or implied, including the warranties of merchantability and fitness for a particular purpose, nor assumes any legal liability or responsibility for the accuracy, reliability, completeness or utility of these geospatial data, or for the improper or incorrect use of these geospatial data. The Frasch industry was developed in the early 20th century and uses superheated water injected into underground sulphur deposits to melt the sulphur, which is then brought to the surface through sulphur wells. this group, the explorer Antoine Simon Le Page du Pratz may be considered In 1987 the company began to acquire newly opened low cost leases in the shallow waters of the Gulf of Mexico. by Fr. fishing, particularly for shrimps and oysters; a major source of The magazine went on to comment that LL&E's finding and developing costs were among the industry's highest and noted that the company had closed its Michigan copper mine after completing work on a $78 million dollar copper smelter. See, e.g. All Rights Reserved 312, 318 (1976)), the evidence in this case does not justify our ignoring the parties' stipulation. In 1984, the Supreme Court considered the effect of section 613A on percentage depletion of oil and gas income and concluded that sections 611-613A permit an allowance for percentage depletion on lease bonuses at some point during the productive life of the lease, regardless of when actual production of oil and gas occurred. There is no question that there are no particular gas reserves governed by warranty contracts entered into by Texaco. This definition encompasses both hydrocarbon and nonhydrocarbon gases. The minerals in the water are not developed for commercial use, and the brine water is reinjected into the well reservoir to maintain pressure. Section 613A(b), providing percentage depletion for "regulated natural gas" and "natural gas sold under a fixed contract" also makes sense only if section 613A applies solely to hydrocarbon fuels. THE LOUISIANA LAND AND EXPLORATION COMPANY DONATES THE ISLES DERNIERES CHAIN OF ISLANDS TO THE STATE OF LOUISIANA. In addition, in December 1976 LL&E acquired the Warrior River Coal Company, owners of a small surface mine in Tuscaloosa, Alabama. 979 (1961), affd. Of the company's 225 million barrels of oil equivalent reserves, nearly 60 percent are garnered from domestic sources. We aim to provide a wide range of injection molding services and products ranging from complete molding project management customized to your needs. Following respondent's reasoning, "natural gas" for purposes of section 613A means any product extracted from an oil and gas well in a gaseous state. Second, percentage depletion is permitted for so much of a taxpayer's "average daily production" of domestic crude oil or natural gas as does not exceed the taxpayer's "depletable oil quantity" or "depletable natural gas quantity." Oil and gas often become trapped in the pockets that form around these structures.) Company HistoryOil & Natural Gas Extraction. WebProperties Operated by Louisiana Land & Exploration Co View All Properties Operated by Louisiana Land & Exploration Co Recent Permits Filed by Louisiana Land & Exploration Co Company Contact Information These are the contact records we have for Louisiana Land & Exploration Co. Pub. By 1970, an oversupply of sulphur seriously depressed prices,4 but the sulphur market recovered and the price of sulphur rose dramatically in the late 1970's and early 1980's.5. 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. Lease No. The brine water is reinjected into the well. 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. Respondent has stipulated that if we find petitioners are entitled to percentage depletion deductions, they correctly computed the amount of the depletion deductions on their Federal income tax returns. Therefore, we hold that the district court correctly concluded that Section 109 of the NGPA regulates the ceiling price for the gas in question. It soon became apparent that the land owned by Louisiana Land and Exploration, as the company was renamed in 1927, was rich in petroleum resources. At Furnel, Inc. we understand that your projects deserve significant time and dedication to meet our highest standard of quality and commitment. We further conclude that section 613A applies only to hydrocarbon fuels produced from oil and gas wells and does not affect eligibility for percentage depletion for other minerals produced from oil and gas wells. A "warranty" contract is an arrangement whereby the producer is obligated to deliver to the purchaser certain quantities of gas; the source of the gas is unspecified and the producer may therefore fulfill his obligation from any source he chooses. 204(c)(2), 44 Stat. This released acreage amounted to approximately 557,000 acres. Moreover, the legislative record tends to show that Congress believed it was not restricting percentage depletion under section 613 for any minerals except oil and gas. 1.613-2(b)(4), Income Tax Regs.10 Section 613(b)(1)(A), which provides for percentage depletion at a rate of 22 percent for sulphur, has no limitation based on the source of the sulphur. By year's end, Phillips could boast of $94 million in profits on sales of $1.25 billion. In 1975 the company opened a small refinery in Mobile, Alabama, to process 30,000 barrels a day of Jay Field crude. ; Shamrock Oil & Gas Corp. v. Commissioner, 35 T.C. On this reasoning, respondent concludes that "natural gas" within the meaning of section 613A includes all gases produced from an oil and gas well because all such gases are depletable under section 611. There are no known limits on the percentage of hydrogen sulfide a well can contain and still remain economically viable as a source of oil and gas. Section 613(b)(7) provides for percentage depletion at 14 percent for "all other minerals" except: Because petitioners' sulphur was not extracted from a mine but from hydrogen sulfide produced from oil and gas wells, respondent argues that the income from the sulphur is depletable, if at all, pursuant to section 613(b)(7) as an "other mineral." The data are dynamic and may change over time. 123673km/47752sqmi. Section 613A(e)(1) defines "crude oil" as including "a natural gas liquid recovered from a gas well in lease separators or field facilities." WebThe Louisiana Land and Exploration Co. (LLEC) (defendant) claimed that it was the actual owner of the land between the Liners recorded title boundary and Bayou Dufrene. Louisiana Land & Exploration Co. is a corporation lessee based in New Orleans, Louisiana for 11 oil and gas leases8 are authorized and 2 are closed. Click to open an interactive map. Oil and Gas lease entities located at the same street address in New Orleans, Louisiana as Louisiana Land & Exploration Co.. During the 1960s, CEO Fred Graham began a process of diversification that would eventually include a Hawaiian resort, a coastal industrial real estate operation, and coal, gold, and copper mines. When we have a project we'll go to Houston, rent a computer and run it through. Canada by the British in the 18th-c); areas devastated by Hurricane WebThe Louisiana Land & Exploration Co is listed as an officer of another company. Between 1978 and 1980 LL&E's sales jumped from $549.4 million to $1.075 billion while earnings increased from $94.8 million to $180.2 million, despite $64 million in 1980 windfall profits taxes. Furnel, Inc. has been successfully implementing this policy through honesty, integrity, and continuous improvement. Through its subsidiary, The Louisiana Land and Exploration Company LLC (LL&E), ConocoPhillips is the largest private wetlands owner in Louisiana. WebThe Louisiana Land and Exploration Company 909 Poydras Street P.O. Milling, Benson, Woodward, Hillyer, Pierson & Miller, Charles D. Marshall, Jr., Appeal Counsel, David N. Schell, Jr., New Orleans, for plaintiff-appellee Louisiana Land and Exploration Co. Gene W. Lafitte, Appeal Counsel, George J. Domas, Anne E. Tate, Liskow & Lewis, and Frederick W. Veters, Patrick J. Butler, Larry N. Port, Robert E. Plumb, Jr., James D. Hurley, Texaco Inc., New Orleans, for defendant-appellant Texaco, Inc. 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. Graham worked hard to keep expenses down. Natural hazards may or may not be depicted on the data and maps, and land users should exercise due caution. In 1975 the Kalua Koi Corporation, LL&E's 50-percent-owned Hawaiian operation, began construction on the first phase of a 298-unit hotel condominium complex. 613A(e)(2). Construction began on a new catalytic reformer that would provide more highly valued refined products. Headquartered in New Orleans, it operates a crude oil refinery near Mobile, Alabama, and conducts exploration and production operations in the United States and selected foreign countries. 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. The Louisiana Land and Exploration Company LLC has 581 employees, and the revenue per employee ratio is $481,927. be cited: Jean-Bernard Bossu, Franois-Marie Perrin du Lac, Listed below are the cases that are cited in this Featured Case. 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. Seeking new profit sources and seeing links between fossil fuels and mineral extraction, Phillips laid out $51 million for the Copper Range Company in May 1977. THE LOUISIANA LAND AND EXPLORATION COMPANY AND SUBSIDIARIES, PETITIONERS Representative William Green introduced an amendment to repeal percentage depletion for oil and gas during the floor debates in the House but the Senate Finance Committee deleted the provision. This appeal stems from the granting of a motion for partial summary judgment in favor of the Louisiana Land and Exploration Company (LL & E). Wolf Exploration Company shall, as to such leases, be entitled to the same overriding royalty, provided for hereinabove in paragraphs 1.1.1 through 1.1.5. Congress chose 6,000 to one as the conversion ratio because one barrel of oil has the equivalent heating value of 6,000 cubic feet of "natural gas." ", But while Graham focused on controlling costs, he, like other CEOs of that era, also sought profits in new businesses. Rightor and John Kendall Smith. the first historian of Louisiana with his. The sulphur is then condensed and stored until sold. The sales Section 611(a) allows as a deduction in computing taxable income from natural resources a reasonable allowance for depletion. Respondent thus argues that because the sulphur in issue is a product of oil and gas wells, it loses its section 613 depletion allowance. After winning the proxy fight in 1983, Phillips sold LL&E's coal properties and bought back 71 million shares for $212.8 million. Rec. To do this, he committed major amounts of capital to new exploration initiatives. Rec. 121 Cong. (c) EXEMPTION FOR INDEPENDENT PRODUCERS AND ROYALTY OWNERS., (1) IN GENERAL.Except as provided in subsection (d), the allowance for depletion under section 611 shall be computed in accordance with section 613 with respect to. The capital stock of LL E is registered with the Securities and Exchange Commission ("SEC") and is traded on the New York Stock Exchange. The state's principal agricultural outputs include seafood Congress thus retained percentage depletion for small, independent producers to encourage domestic production. William M. Linden, Ewing Werlein, Jr., Christine L. Vaughn, John W. Leggett, and Elaine Drodge Koch, for the petitioners. We receive lots of emails from people who find their name or a relatives name on our site and want to know if this means they have some right to the land listed under that name. The Drillings accepts no liability for the content of this data, or for the consequences of any actions taken on the basis of the information provided. LL & E's position is that Section 105 does not determine the ceiling price for this gas because the gas is not "subject to" any contract; instead, the LL & E gas is being used to fulfill these particular contracts solely because Texaco has chosen to use it rather than to use gas from other reserves. 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. We must decide whether section 613A eliminates the section 613 percentage depletion rate on sulphur when hydrogen sulfide is produced from an oil and gas well and subsequently converted into elemental sulphur. Discover petroleum exploration activity in your area and find new regions of opportunity. Rec. Information hosted on The Drillings is based on publicly available data through the Bureau of Land Management. Crude oil is measured and sold by barrels. tax rate is 1 percent: a .97 percent Louisiana sales tax 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. 7295-7296 (1975). Sec. The, first commercial plant in the United States to use the modified Claus process was placed in operation in 1944. Rec. (A salt dome is a raised central area of salt or rock, around which beds of sedimentary rock dip in all directions. Citations are also linked in the body of the Featured Case. Petitioners are calendar year, accrual method taxpayers. In 1960 Youngs signed a second contract with Texaco that subjected 275,625 additional acres to six years of exploration and development. This figure included $181 million for 215 wells; $64 million for leases in Wyoming, the Gulf of Mexico, Australia, Indonesia, Columbia, and the North Sea; and $286 million for construction at Brae Field, platforms in the Gulf of Mexico, and a tertiary recovery project at Jay Field. In 1988 crude prices fell by more than $3 a barrel and newly named CEO and chairman H. Leyton Steward was forced to take an $81.8 million restructuring charge and a $33.3 million loss. L. 94-12, sec. 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.). and its Licensors This uncontradicted and consistent legislative record, therefore, reveals that Congress was concerned only with oil and gas when it approved section 613A. cattle, sugarcane, poultry and eggs, dairy products, and Products; Resources; My Account; Talk to a D&B Advisor 1-800-280-0780. Business Directory. In 1964 the company reported profits of $32.1 million on sales of $64.1 million. In determining this price, Texaco claims that Section 105 of the NGPA, entitled "Ceiling price for sales under existing intrastate contracts," is applicable. Rec. A number of members criticized the provision for unfairly singling out the oil and gas industry. (a) GENERAL RULE.In the case of the mines, wells, and other natural deposits listed in subsection (b), the allowance, for depletion under section 611 shall be the percentage, specified in subsection (b), of the gross income from the property excluding from such gross income an amount equal to any rents or royalties paid or incurred by the taxpayer in respect of the property. Natural gas, in contrast, is a broad concept encompassing many types of gases and is, therefore, more difficult to define. WebThe Louisiana Land and Exploration Company Law Practice New Orleans, Louisiana 10 followers Commissioner v. Engle, 464 U.S. at 218.

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