Taxation of Oil and Gas Income

2nd Cir 5th Cir acquired aff'd allocated amount applicable association taxable attributable Bonwit Teller Canadian carried interest carved-out oil payment cash cent co-owners Commissioner computing considered contribution corporation cost depletion Court delay rentals depletion allowance depreciation development costs drill and equip drilling and development dry hole duction entitled equipment costs erty exchange expenditures fair market value gas property grantee grantor gross income held Helvering Income Tax Act incurred Internal Revenue Code issue lease bonus leasehold cost lessee ment mineral net income nonacq nonoperating interest oil and gas Oil Company oil or gas operating interests ordinary income overriding royalty owner P-H T.C. Memo paid Paragraph Number partnership percentage depletion petroleum portion production profits interest prop property interest provisions received regulations retained Revenue Service rule Section separate Statutes of Canada supra tax consequences tax purposes taxpayer tion trade or business transaction treated U.S. Treas United Wilshire Oil Co