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. French explorers, among whom the following at least should The Louisiana Land and Exploration Company (LL&E) is one of the largest independent oil and gas exploration companies in the United States. THE LOUISIANA LAND AND EXPLORATION COMPANY DONATES THE ISLES DERNIERES CHAIN OF ISLANDS TO THE STATE OF LOUISIANA. 612. Phillips, however, remained committed to Copper Range. Pub. If gases that are never used as fuels, such as hydrogen sulfide, were considered natural gases for purposes of section 613A(c), the conversion ratio would be nonsensical. The liquid hydrocarbon produced from the Jay Field wells is crude oil, which consists of hydrocarbon compounds that are in a liquid phase at ambient temperature and pressure. When section 613A(e)(2) is read in conjunction with sections 611 and 613, together they function as a filter to exclude depletion allowances for anything produced from an oil and gas well except as permitted by section 613A(b) and section 613A(c). This released acreage amounted to approximately 557,000 acres. During the 1950s, CEO Robert M. Youngs began investing in working interest wells. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT, United States Tax Court.https://leagle.com/images/logo.png. Continuing to diversify, in 1968 Graham obtained the rights to participate in the resort development of approximately 50,000 acres on the western half of Molokai Island, Hawaii--an island previously best known for its leper colony. Rec. Nevertheless, respondent himself has articulated his belief that the "natural gas" referred to in section 613A is "hydrocarbon gas." 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. 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. Brine water, water with a high mineral content, is the nonhydrocarbon liquid extracted from the Jay Field wells. In 1955 it reported $13.4 million in profits on sales of $22.4 million. Spots was recovered from an adjoining area in 1986 by the original land owners, Louisiana Land and Exploration Company, and lived on the grounds until he was donated to the Audubon Zoo in 1990. 613A(e)(2). The Louisiana Land and Exploration Company LLC revenue is $280.0M annually. Respondent argues that the amendments to section 613 were intended to eliminate percentage depletion not only for oil and gas but also for all other minerals produced from oil and gas wells except as provided in section 613A. If independent producers cannot claim percentage depletion for the sulphur they may recover from hydrogen sulfide before selling the hydrocarbon fuels extracted from an oil and gas well, there is less economic incentive to explore for and exploit new wells, particularly sour gas wells. Discover petroleum exploration activity in your area and find new regions of opportunity. Regulated natural gas is gas regulated by the Federal Power Commission, which regulates only the price of fuels. Leagle.com reserves the right to edit or remove comments but is under no obligation to do so, or to explain individual moderation decisions. WebLOUISIANA LAND AND EXPLORATION, COMPANY, THE was registered on Nov 12 1974 as a foreign profit corporation type with the address 225 BARONNE ST., NEW ORLEANS, LA, "Our organization," he told Dun's "is the non-rigid, non-army type. (various editions, culminating in 1866, 4 vols., with a In Herring v. Commissioner, 293 U.S. 322, 328 (1934), the Court held that the taxpayers were entitled to percentage depletion on bonuses received as advance payments for oil and gas to be extracted even though the well was not yet in operation, reasoning that the right to depletion was not conditioned on the existence of a well.11. He notes that the "oil and gas well" language has been in the Code since percentage depletion was enacted in 1926 and argues that Congress would have changed it if it intended only to limit oil and gas depletion. Here is a summary of how the competitors of The Louisiana Land and Exploration Company LLC compare to one another: Vastar Resources has the most employees (1,151). Respondent interprets section 613A(e) as follows: Section 613A(e)(2) provides a definition; it is not an allowance section. In general, while cost depletion continued to be available, section 613A eliminated percentage depletion for gross income from oil and gas for major integrated oil companies. And they paid us a $4 million bonus on the lease!". Steward used excess cash flow--including $198 million from asset sales&mdash repurchase nearly 2.6 million shares and reduce LL&E's total debt by one-third. Follow WebThe La Land & Exploration Co U 004: API No. pop(2000e) 4469000; area (1) CRUDE OIL.The term "crude oil" includes a natural gas liquid recovered from a gas well in lease separators or field facilities. In no case shall the allowance for depletion under section 611 be less than it would be if computed without reference to this section. Lease No. The following June a wholly owned subsidiary of LL&E, the Sun Fire Coal Company, began to develop an underground mine near Hazard, Kentucky. Accordingly, we affirm the partial summary judgment granted by the district court and remand the case for a determination of damages. The user is responsible to verify the limitations of the geospatial data and to use the data accordingly. 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. Section 613(b) in general provides the list of minerals that are eligible for percentage depletion and specifies the percentage depletion rates. A number of members criticized the provision for unfairly singling out the oil and gas industry. Sulphur is mentioned once in the congressional debates as part of a list of 108 mineral extractive industries for which percentage depletion was retained. Sulphur is not depletable under section 613(b)(7) because depletion for sulphur is expressly provided for in subsection (b)(1). In this case, the district court determined that Texaco is liable to LL & E for paying royalties calculated upon the value of the gas as determined under the Section 105 contract price rather than the Section 109 ceiling price. the first historian of Louisiana with his. to a substantial portion of the, New Orleans metropolitan Escalating energy prices and the Arab oil embargo awakened the public to the Nation's growing reliance on foreign energy resources. v. LL&E enjoyed a good exploration year in 1990. 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 typical well stream in the Jay Field contains approximately 8.5 percent hydrogen sulfide and 2.2 percent carbon dioxide. 613(b)(1)(A). Listed below are the cases that are cited in this Featured Case. In the contract, which was very generous for its time, Texaco agreed to pay LL&E a 25-percent royalty on production and 8 percent of its net profits on a dome-by-dome basis. 121 Cong. Under the agreement, LL&E retained a 25 percent working interest and a 20 percent royalty in Texaco's share of production. 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. R.S. 4638 (1975); S. Rept. Respondent further argues that Congress would not have used the term "oil and gas wells" as opposed to simply "oil and gas" if it had not intended to limit percentage depletion for all products of oil and gas wells. Red, Sabine, and Pearl; highest point Mt Driskill This section provides, in pertinent part: Relying on this Section, Texaco has been paying royalties to LL & E based upon the contract prices specified by the warranty contracts which Texaco has been servicing with the LL & E gas. area, List of school districts in Graham worked hard to keep expenses down. The company was incorporated in 2010 and is based in New Orleans, Louisiana. Sec. After winning the proxy fight in 1983, Phillips sold LL&E's coal properties and bought back 71 million shares for $212.8 million. The carbon dioxide is vented to the atmosphere. As LL&E expanded its exploration efforts (by 1974 it was exploring in southern Louisiana, the Rocky Mountain area, a geological stratum from northern Louisiana to Florida, and off the coasts of Louisiana and Texas) it began to act as operator in an increasing number of its working interest efforts. Click on the case name to see the full text of the citing case. 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. 4606 (1975). Outside of Louisiana, Youngs acquired mineral rights and royalty interests on 152,870 acres in Texas, New Mexico, North Dakota, South Dakota, Montana, Colorado, Florida, and Mississippi. and paper industry; highly productive in agriculture; soybeans, Section 613A(e) defines crude oil and natural gas for purposes of section 613A. Shell Oil Co., v. Williams, 428 So.2d 798 (La.1983). (Lafayette), New Orleans Jazz National Historical Copyright 2023 Web Solutions LLC. The company had few employees and operators shouldered the major expenses of exploration and development. During the early 1980s, lackluster exploration results and fluctuating prices destabilized the company's finances and forced it to sell its non-oil and gas efforts and concentrate on finding new low-cost reserves. The standard history of the state, though only through Caspary's charges had some legitimacy. Mexico; rivers include the Mississippi (large delta area in the S), There are generally two types of marketing contracts for the sale of gas. By 1964, non-royalty, working-interest or joint-venture income had increased to 45 percent of LL&E's total sales. Sec. The primary issue on appeal is whether that value should be determined under Section 105 of the NGPA, as Texaco argues, or under the higher ceiling price reflected in Section 109 of the NGPA, as LL & E claims. To make up for this, LL&E participated in additional working interest wells and in 1970 discovered a major reserve estimated at 720 million barrels of oil in the Jay Field in Santa Rosa, Florida. As the largest owner of environmentally sensitive wetlands in the continental United States, LL&E had long been careful to protect its investment. The Louisiana Land and Exploration Company LLC is a relatively young 7295. It was solely Texaco's choice to meet its obligations to these customers with LL & E's gas. 1971). Mascrier), Fr. around New Orleans; special population groups of Creoles (French In 1984 Phillips was replaced by E. L. Williamson, who worked to sustain profit margins and increase reserves. A literal reading, however, aims the statutory restrictions on percentage depletion at any mineral produced along with oil or gas when the legislative record of section 613A's passage is wholly devoid of mentioning any such important targets. 16. Of course, hydrogen sulfide is a gas naturally occurring in exhaustible deposits in the earth and falls within a technical classification of "natural gases." 613A(c)(4). No damages have yet been proven, and indeed, the partial summary judgment would be proper even if none are ever established. Both are part of the PLSS measurement system but have different uses. We, therefore, hold that pursuant to section 613(b), petitioners are entitled to percentage depletion deductions in the amounts stipulated for sulphur produced from oil and gas wells. In 1974 Jacinport reported $2 million in real estate sales. Due to higher prices for refined copper, the mining operation even turned a profit of $9.7 million in 1979. Much of the land was eventually taken over by a group of midwesterners led by Henry Timken, who owned an Ohio ball bearing company. There is no indication that Congress intended to limit percentage depletion for any products of oil and gas wells other than hydrocarbon fuels.12.
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