Oil and Gas: Federal Income Taxation, Issue 1

10th Cir 5th Cir acquired ad valorem taxes adjusted basis aff'd agreement allocated allowed amount applicable asset assignment basis Board of Tax bonus capital carried interest carved-out cash consideration CCH Dec cent Comm Commissioner computing contract corporation cost depletion decision delay rentals depletion deduction depreciation development costs drilling and development duction economic interest election equipment expenses Fifth Circuit gas in place gas lease gas production gross income held Helvering intangible drilling joint operating agreements land leasehold lessee lessor loss ment oil and gas oil payment operating ordinary income overriding royalty owner paid partnership payable percentage depletion Petroleum prior proceeds production payment profit interest received regulations reserve ratio retained Revenue Service royalty interest rule Section separate property share subject to depletion sublease Supp Supra note Supreme Court Tax Appeals Tax Court taxable income taxpayer thereof tion tract transaction USTC