Home/Tenth Circuit/Gates Rubber Company, and Subsidiaries v. Commissioner of Internal Revenue

Gates Rubber Company, and Subsidiaries v. Commissioner of Internal Revenue

694 F.2d 648, 51 A.F.T.R.2d (RIA) 628, 1982 U.S. App. LEXIS 23620
CourtCourt of Appeals for the Tenth Circuit
DecidedDecember 3, 1982
Docket81-1523
StatusPublished
Cited by7 cases

This text of 694 F.2d 648 (Gates Rubber Company, and Subsidiaries v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gates Rubber Company, and Subsidiaries v. Commissioner of Internal Revenue, 694 F.2d 648, 51 A.F.T.R.2d (RIA) 628, 1982 U.S. App. LEXIS 23620 (10th Cir. 1982).

Opinion

PER CURIAM.

In this appeal we are asked to decide whether the costs of drilling offshore exploratory oil and gas wells from mobile rigs are deductible in the year in which they are incurred as “intangible drilling and development costs” under 26 U.S.C. § 263(c) and Treas.Reg. § 1.612-4(a) (“the IDC option”). The Tax Court, 74 T.C. 1456, ruled in favor of the taxpayer and against the Commissioner.

All parties agree that the issue in this case is identical with the prior consideration of this issue by the Third Circuit in Sun Co. v. Commissioner, 677 F.2d 294 (3rd Cir.1982). The Third Circuit held for the taxpayer. We agree with the Third Circuit.

AFFIRMED.

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Bluebook (online)
694 F.2d 648, 51 A.F.T.R.2d (RIA) 628, 1982 U.S. App. LEXIS 23620, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gates-rubber-company-and-subsidiaries-v-commissioner-of-internal-revenue-ca10-1982.