Forbes later criticized the Jacintoport purchase, maintaining that LL&E had gotten into industrial real estate, "just at the time when the play was going out of it along the Gulf Coast.". 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. Its price is not regulated by the Federal Power Commission. Also, the company opened its first regional office in Shreveport, LA after acquiring the oil and gas division of T.L. Subsection (e)(2) defines "natural gas" as "any product (other than crude oil) of an oil or gas well if a deduction for depletion is allowable under section 611 with respect to such product." 30:29 (referred to as Act 312), this oilfield remediation case involved the Vermilion Parish School Board (VPSB), individually and on The Louisiana Land and Exploration Company LLC operates as a subsidiary of ConocoPhillips. 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. The Drillings is a resource for locating where oil and gas leases are and have been. 7239 (remarks of Senator Hollings). See 121 Cong. Costs were low at $3.23 per barrel and by year's end, LL&E's reserve life index stood at 8.4 years, nearly double that of 1980. Petitioners are calendar year, accrual method taxpayers. percent. Gayle Land Exploration Co specializes in Oil And Gas Exploration Services. No damages have yet been proven, and indeed, the partial summary judgment would be proper even if none are ever established. These moves strengthened LL&E's overall position, but plunging oil prices and the Copper Range charge took their toll. The property has been operated as a hunting lodge since the 1960s. Hydrogen sulfide is not transported far from the well because of the hazards involved. Until 1982, the Frasch mining industry was the dominant source of sulphur in the world. growth rate 2000?2005, Cane River National Heritage Area near Field / Formation: LAKE DES ALLEMANDS / THE LA LAND & EXPLORATION CO U 004: Well Status: DRY AND PLUGGED: Well Type: Township Range Section: 13S 19E 022: Derrick Elevation: Members Only: Kelly Bushing Elevation: Percentage depletion for natural resources has been a part of the Internal Revenue Code since the Revenue Act of 1926. William M. Linden, Ewing Werlein, Jr., Christine L. Vaughn, John W. Leggett, and Elaine Drodge Koch, for the petitioners. A number of travel relations by 17th and 18th century 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. In the 1950s, CEO Robert M. Youngs began to guide LL&E into other exploration, both on its own lands and on land it leased in other U.S. areas of production. In no case shall the allowance for depletion under section 611 be less than it would be if computed without reference to this section. While entities may have multiple locations, this is based on the address registered for the lease. Oil and gas often become trapped in the pockets that form around these structures.) The carbon dioxide is vented to the atmosphere. Rec. (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. ; Shamrock Oil & Gas Corp. v. Commissioner, 35 T.C. Phillips, meanwhile, continued to diversify. As on previous occasions, LL&E's involvement was a financial one. 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. Respondent thus argues that because the sulphur in issue is a product of oil and gas wells, it loses its section 613 depletion allowance. WebThe company's petroleum operations are conducted in the continental United States, the federal offshore area in the Gulf of Mexico, the North Sea, Colombia, and Indonesia. Rule 91(e), Tax Court Rules of Practice and Procedure. During these years, LL&E did virtually no operating of its oil projects. Section 613A(e) defines crude oil and natural gas for purposes of section 613A. In exchange for this, Texaco would retain one-half of the royalties and profits payable to LL&E up to the amount of $800,000. Due to higher prices for refined copper, the mining operation even turned a profit of $9.7 million in 1979. WebLouisiana Land & Exploration Co/The - Company Profile and News - Bloomberg Markets Bloomberg Anywhere Remote Login Manage Products and Account Information Indices tourism. 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. Instead, we find that the value of the gas within the terms of the leases is a disputed factual issue to be determined at the hearing on damages. Hydrogen sulfide is never used as a fuel and is not sold under long-term fixed price contracts. Rul. 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. Natchez, Jean Lafitte National Historical Park and Hydrocarbons are organic compounds containing only hydrogen and carbon and are most commonly used as fuels. As the company expanded into working interests, it hired geologists, geophysicists, and engineers. 7295. The well effluent from the Jay Field wells is treated in facilities adjacent to the wells. This released acreage amounted to approximately 557,000 acres. By 1964, non-royalty, working-interest or joint-venture income had increased to 45 percent of LL&E's total sales. 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. In a vessel called a contactor, an amine solution such as sulfinal is added to the sour gas. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT, United States Tax Court.https://leagle.com/images/logo.png. (It is the biggest producer of crawfish in the world), cotton, soybeans, Pursuant to section 613A, oil and gas wells qualify for percentage depletion in narrowly limited circumstances. Deteriorating economic conditions, windfall profits taxes, high dry hole costs, narrower profit margins, and declining demand all pressured earnings. pelts, especially muskrat; second only to Texas in oil and natural WebLouisiana Land & Exploration Co. PO Box 60350 New Orleans , Louisiana 70160 Louisiana Land & Exploration Co. is a corporation lessee based in New Orleans, Louisiana for 11 oil Cf. In 1965 LL&E had only 145 employees. This criticism was borne out in December of that year when Lloxy paid $60 million for Gulf leases covering land under 300 feet of water. We offer full engineering support and work with the best and most updated software programs for design SolidWorks and Mastercam. Some thought the major integrated oil companies were reaping excessive oil and gas profits at the public's expense, while reinvesting little of their concomitant tax depletion subsidies in domestic energy production. By year's end, Phillips could boast of $94 million in profits on sales of $1.25 billion. 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. 82-17, 1982-1 C.B. Foreign reserves are located in the U.K. and Dutch sectors of the North Sea, Canada, and Columbia. 4606 (1975). and its Licensors It insisted that drillers bury pipe so as to not disrupt grasses or aquatic life, and it constructed pumps and water control structures to prevent erosion or saltwater intrusion. The sales Petitioners contend that section 613A applies only to hydrocarbon fuels and that sulphur, which is not a hydrocarbon, is depletable under section 613(b)(1). When we have a project we'll go to Houston, rent a computer and run it through. The separated sour crude oil undergoes further treatment within the oil stabilization system, a pressurized vessel in which heat vaporizes and removes more of the dissolved sour gas (i.e., hydrogen sulfide, carbon dioxide, and natural gas). Accordingly, we affirm the partial summary judgment granted by the district court and remand the case for a determination of damages. be cited: Jean-Bernard Bossu, Franois-Marie Perrin du Lac, According to LL & E, the ceiling price for the gas is fixed by Section 109 of the NGPA, which provides, in pertinent part: In granting LL & E's motion, the district court found that although the gas was being "sold under" contracts existing when the NGPA was adopted, as is required by subsection (a) of Section 105, this fact was not enough to submit the gas to the Section 105 price limitation. These geospatial data and related maps or graphics are not legal documents and are not intended to be used as such. Preserve, headquartered in New Orleans, with units in Louisiana Land and Exploration Company (LL E) filed this possessory action on November 12, 1992, relating to two sections of marshland property (Sections 27 and 28, Township 19 South, Range 20 East) in Lafourche and Terrebonne Parishes and seeking to stop the individual defendants from their alleged acts of trespass and damage on the property. Louisiana Historical Society and several works Oil and gas have been extracted from wells containing a trace quantity of hydrogen sulfide and from wells containing as much as 90-percent hydrogen sulfide. St. Bernard Parish, Baritaria (Crown Point), and Acadiana 17-023-20688: Well Direction: Operator: MCMORAN EXPLORATION COMPANY: Lease No. (A salt dome is a raised central area of salt or rock, around which beds of sedimentary rock dip in all directions. The company continued to look for new sources of oil and in October 1972 newly named CEO John G. Phillips announced a $75 million offering to finance a new subsidiary, Louisiana Land Offshore Exploration Co. (Lloxy), that would explore for oil and gas in the Gulf of Mexico. 95. Petitioners, the Louisiana Land & Exploration Co. (LL&E) and Subsidiaries, are an affiliated group of corporations whose common parent is LL&E. 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. cattle, sugarcane, poultry and eggs, dairy products, and 6903 (1975) (statement of Senator Bentsen). Escalating energy prices and the Arab oil embargo awakened the public to the Nation's growing reliance on foreign energy resources. Rec. 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.. This web site and associated pages are not associated with, endorsed by, or sponsored by The Louisiana Land And Exploration Company and has no official or unofficial affiliation with The Louisiana Land And Exploration Company. and a .03 percent Louisiana Tourism Promotion District sales The nonhydrocarbon gases extracted from the Jay Field wells are primarily hydrogen sulfide and carbon dioxide. gas production (mainly offshore); oil refineries and petrochemical First, percentage depletion is permitted with respect to certain domestic gas wells for regulated natural gas, natural gas sold under a fixed contract, and natural gas from geopressured brine. Texaco pays 75 percent and gets 60 percent. Sec. Forbes called Copper Range "a company so bad that some analysts wondered whether it was acquired to make Louisiana Land unattractive as a takeover candidate." 4625 (remarks of Representative Pickle) ("if we are going to repeal the depletion allowance in one area, * * * we need to look at the depletion allowance on these other minerals"). In 1984, large additions and renovations were made to the lodge, increasing the size of the camp to accommodate more guests. Construction began on a new catalytic reformer that would provide more highly valued refined products. Petitioner argues that the definition of "natural gas" in section 613A(e)(2) is intended only to distinguish between hydrocarbon natural gases and crude oil. A number of cities in Louisiana are also home to Jewish communities, The diagram on the facing page summarizes the sour production processing system used at the Jay Field Wells. 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. 17-057-02316: Well Direction: Operator: HUMBLE OIL AND REFINING CO. posthumous and further expanded edition in 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 venture's finances faltered and in time there were foreclosures. Congress responded to this public outcry by repealing the percentage depletion allowance as applied to the major integrated oil companies.". 30292-85, 37799-85, 47753-86. The acid gases (hydrogen sulfide and carbon dioxide) are separated from the natural gas through an absorption process. Congress' goal of encouraging domestic production would in that event be thwarted. The Louisiana Land and Exploration Company explores, develops, and produces petroleum natural gas resources. on the history of New Orleans (q.v. In 1989 the Department of Interior recognized this effort and awarded LL&E its Conservation Award for Respecting the Environment. rice. This definition encompasses both hydrocarbon and nonhydrocarbon gases. (a) GENERAL RULE.Except as otherwise provided in this section, the allowance for depletion under section 611 with respect to any oil or gas well shall be computed without regard to section 613. 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. Texaco additionally contends that partial summary judgment was procedurally improper in this case both because the decision did not determine any portion of its liability to LL & E and because there are issues of disputed fact that prevent summary judgment. In Rev. "It was a very unusual contract for 1928," LL&E president Ford Graham told Dun's Review in 1965. petroleum and 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. It was solely Texaco's choice to meet its obligations to these customers with LL & E's gas. Sec. In 1980, LL E earned profits of 180.2 million dollars or $4.74 per share. Raising this argument for the first time in his post-trial brief, respondent would argue a case that petitioners were unable to develop for trial and would, consequently, prejudice petitioners' case. the more important, as well as the publications of the ", But while Graham focused on controlling costs, he, like other CEOs of that era, also sought profits in new businesses. LLEC began attempting to mark that boundary, first with a ditch and later by removing the Liners stakes at the edges of their claimed land. The floor debates are replete with references to what some members believed to be huge profits enjoyed by the major integrated oil companies and a concomitant lack of need for percentage depletion for oil and gas income. Current estimates show that the unit has a sales volume of $1500000 and staff of approximately 17 people. "The normal royalty was one-eighth (12 percent). 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. The state's principal agricultural outputs include seafood WebIn 1946, this original structure was acquired from the Sun Oil Company and transported by barge from Cocodrie, LA to its current location in Paradis. In the case of oil and gas wells, "gross income from the property" has been interpreted to mean gross income from the sale of the property at the "well-mouth," i.e., before conversion or transportation. Sulphur is depletable pursuant to section 613(b)(1) and not section 613(b)(7). And they paid us a $4 million bonus on the lease!". These apparent anomalies are reconciled, in respondent's view, by attributing to Congress an unexpressed intent to deny any percentage depletion for nonhydrocarbon gases. Depletion generally is calculated based on the cost of the property.

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