We further conclude that section 613A applies only to hydrocarbon fuels produced from oil and gas wells and does not affect eligibility for percentage depletion for other minerals produced from oil and gas wells. 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. pelts, especially muskrat; second only to Texas in oil and natural Since that time, however, the amount of sulphur recovered from hydrogen sulfide has been greater. 346 F.2d 377 (5th Cir. The Louisiana Land and Exploration Company LLC operates as a subsidiary of ConocoPhillips. Of the company's 225 million barrels of oil equivalent reserves, nearly 60 percent are garnered from domestic sources. Foreign reserves are located in the U.K. and Dutch sectors of the North Sea, Canada, and Columbia. LL&E traces its roots to the 19th century, when midwestern businessman Edward Wisner moved to Louisiana for his health. 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. In 1989, the company spun off Plum Creek In 1981 he budgeted a still-record $653 million for exploration and development. Congress responded to this public outcry by repealing the percentage depletion allowance as applied to the major integrated oil companies.". Petitioners rightly assumed that the issue was settled and cannot now justly be required to prove the amount of the depletion deduction to which we have found they are entitled. A number of cities in Louisiana are also home to Jewish communities, THE LOUISIANA LAND AND EXPLORATION COMPANY AND SUBSIDIARIES, PETITIONERS LL&E is a Maryland corporation having its principal office at New Orleans, Louisiana. 613A(e)(2). We conclude that in drafting section 613A, Congress intended to limit percentage depletion only for income from hydrocarbon fuels. Login | Register; Home; Operators; Leases; Wells; Permits; Pricing; Search; Map; Sweet Lake Land And Oil Co 001: API No. Leagle.com reserves the right to edit or remove comments but is under no obligation to do so, or to explain individual moderation decisions. 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. 82-17, 1982-1 C.B. 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. "We pay 25 percent of the cost," Ford Graham enthusiastically told Dun's Review "and get 40 percent of the income. In addition, in December 1976 LL&E acquired the Warrior River Coal Company, owners of a small surface mine in Tuscaloosa, Alabama. 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." cattle, sugarcane, poultry and eggs, dairy products, and 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. this group, the explorer Antoine Simon Le Page du Pratz may be considered After winning the proxy fight in 1983, Phillips sold LL&E's coal properties and bought back 71 million shares for $212.8 million. Hydrogen sulfide and carbon dioxide are contaminants of natural gas.3 Sour gas cannot be used as fuel; the hydrogen sulfide and carbon dioxide must first be removed. "Our organization," he told Dun's "is the non-rigid, non-army type. WebThe Louisiana Land and Exploration Company Overview. Rec. WebThe Louisiana Land and Exploration Company (LL&E) is one of the largest independent oil and gas exploration companies in the United States. Sulphur is depletable pursuant to section 613(b)(1) and not section 613(b)(7). Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case. Current estimates show that the unit has a sales volume of $1500000 and staff of approximately 17 people. The goal of the legislation was to continue to provide the tax incentive of percentage depletion to small producers and royalty owners to encourage exploration for and exploitation of domestic oil and gas reserves while eliminating such tax incentives for the major integrated oil companies. (1975). Section 613(b)(7), however, does not appear to exclude from percentage depletion under section 613 all minerals from oil and gas wells. By year's end, Phillips could boast of $94 million in profits on sales of $1.25 billion. At year's end, he was able to salvage earnings of $76.3 million despite mining operations that sustained a pretax loss of $38 million. French explorers, among whom the following at least should Respondent, however, has entered into a stipulation of facts with petitioner pursuant to which he agreed as follows: Petitioner[s] claimed percentage depletion deductions on sulphur in [their] tax returns in the following amounts: If Petitioner[s'] sulphur production is subject to depletion under section 613(b) of the Code, Petitioner[s] [are] entitled to the sulphur percentage depletion deductions listed above. And when we're finished we don't own the computer or have the people on our permanent payroll. ; Shamrock Oil & Gas Corp. v. Commissioner, 35 T.C. Timken agreed and in 1926 exchanged his acres for shares in the Border Research Corporation. We agree with the district court that Section 109 applies. Forbes criticized the offer, charging that the company had waited too long to get into explorations and would be left with expensive deeper water wells. Learn more about the Bureau of Land Management, Public Land Survey System, and oil and gas leases. The nonhydrocarbon gases extracted from the Jay Field wells are primarily hydrogen sulfide and carbon dioxide. As a result of floor amendments by Senators Kennedy, Hollings, Bentsen, and others, however, the final bill included a provision eliminating percentage depletion for oil and gas wells with certain exceptions primarily for the benefit of small producers and royalty owners. Listed below are those cases in which this Featured Case is cited. An "oil and gas well" is not itself a mineral, and to provide a depletion rate for "all other minerals except * * * oil and gas wells" would seem to require an implied reading that "minerals from" must have been intended. After extensive research and analysis, Zippia's data science team found the following key financial metrics. (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. TEXACO, INC. Court of Appeal of Louisiana, Fourth Circuit.https://leagle.com/images/logo.png. Congress' goal of encouraging domestic production would in that event be thwarted. 7239 (remarks of Senator Hollings). At that time, the lodge housed the Louisiana Land and Exploration Companys crew while they constructed a levee around the 3,000 acre property. The "depletable natural gas quantity" is whatever portion of its depletable oil quantity the taxpayer chooses to convert to natural gas at a conversion ratio of 6,000 cubic feet of gas to one barrel of oil. Only subparagraph (B) includes the words "minerals from." As the largest owner of environmentally sensitive wetlands in the continental United States, LL&E had long been careful to protect its investment. After considering the language, structure and legislative record of the passage of section 613A, we do not believe that section 613A was intended to limit sulphur depletion pursuant to section 613(b)(1). Respondent thus concludes that we should not allow percentage depletion for sulphur derived from hydrogen sulfide. Lease No. 7295. WebThe Louisiana Land and Exploration Company was presented the 1997 National Association of Conservation Districts (NACD) Business Conservation Leadership Award at a luncheon France by La Salle, 1682; most of the E region ceded to Spain in 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). The, first commercial plant in the United States to use the modified Claus process was placed in operation in 1944. tax. The acid gases (hydrogen sulfide and carbon dioxide) are separated from the natural gas through an absorption process. Click on the case name to see the full text of the citing case. See 121 Cong. Lease No. Rec. the Civil War, is Charles Gayarr's History of Louisiana Louisiana Purchase, 1803; admitted to the Union as the 18th state, 1965), cert. Rightor and John Kendall Smith. Gayle Land Exploration Co specializes in Oil And Gas Exploration Services. Its industrial outputs include chemical products, To make matters worse, copper revenues declined and precious metals margins shrank. WebRead Louisiana Land and Exploration Co. v. Donnelly, 394 F.2d 273, see flags on bad law, and search Casetexts comprehensive legal database Louisiana Land and Exploration Co. v. Donnelly, 394 F.2d 273 | Casetext Search + Citator Envisioning farming on a grand scale, Wisner bought hundreds of thousands of acres, built levees, and drained the land. (1) CRUDE OIL.The term "crude oil" includes a natural gas liquid recovered from a gas well in lease separators or field facilities. It appears that the absence of the phrase "minerals from" from paragraph (C) was not an oversight. 17-057-02316: Well Direction: Operator: HUMBLE OIL AND REFINING CO. 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. LL&E enjoyed a good exploration year in 1990. Louisiana. 612. Ronald H. Wednesday, July 9, 1997. Petitioners, the Louisiana Land & Exploration Co. (LL&E) and Subsidiaries, are an affiliated group of corporations whose common parent is LL&E. On November 7, 1938, LL&E and Texaco amended their contract. The acid gas next is separated from the amine solution and passed into a multistage Claus sulphur recovery system, where hydrogen sulfide is converted into molten elemental sulphur by controlled combustion with air. James WebProperties Operated by Louisiana Land & Exploration Co View All Properties Operated by Louisiana Land & Exploration Co Recent Permits Filed by Louisiana Land & Exploration Co Company Contact Information These are the contact records we have for Louisiana Land & Exploration Co. Commissioner v. Engle, 464 U.S. 206, 218 (1984). Rec. Steward announced that LL&E would sell nonstrategic oil and gas properties and use the proceeds to repay long-term debt and repurchase up to 10 percent of outstanding stock. Hydrogen sulfide is never used as a fuel and is not sold under long-term fixed price contracts. 7295. Brine water, water with a high mineral content, is the nonhydrocarbon liquid extracted from the Jay Field wells. Bayou, a National Wild and Scenic River in northern At all relevant times, petitioner sold the sulphur it produced to Freeport Minerals Co. Respondent thus argues that because the sulphur in issue is a product of oil and gas wells, it loses its section 613 depletion allowance. The problem in this case arose because Texaco, in an effort to secure a market for natural gas when it was not a particularly valuable commodity, entered into long term sales agreements with Louisiana industrial consumers promising future delivery of gas at what are now below-market prices. 613A(c)(4). 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. WebArising under the 2006 version of La. Discover petroleum exploration activity in your area and find new regions of opportunity. Pub. The same year he paid $486 million for Inexco Oil Co., an oil company with reserves that included 9.9 million barrels of liquids and 392.7 million cubic feet of domestic natural gas reserves. That year the company also saw initial returns from both the tertiary recovery project at Jay Field and the "A" platform of the Brae Field in the North Sea. We aim to provide a wide range of injection molding services and products ranging from complete molding project management customized to your needs. Louisiana Land & Exploration Co. is a corporation applicant based in New Orleans, Louisiana for 66 closed leases. 94-36, 94th Cong., 1st Sess. petroleum and The magazine went on to comment that LL&E's finding and developing costs were among the industry's highest and noted that the company had closed its Michigan copper mine after completing work on a $78 million dollar copper smelter. Regulated natural gas is gas regulated by the Federal Power Commission, which regulates only the price of fuels. Section 613A(e)(1) defines "crude oil" as including "a natural gas liquid recovered from a gas well in lease separators or field facilities." William M. Linden, Ewing Werlein, Jr., Christine L. Vaughn, John W. Leggett, and Elaine Drodge Koch, for the petitioners. (b) EXEMPTION FOR CERTAIN DOMESTIC GAS WELLS.. Preserve, headquartered in New Orleans, with units in Box 60350 New Orleans, Louisiana 70160 U.S.A. (800) 351-1242 Fax: (504) 566-6891 Public Company The sulphur is then condensed and stored until sold. In 1980, LL E earned profits of 180.2 million dollars or $4.74 per share. These could be different entities opperating out of the same locationlike a shared office space, PO Box, or family homeor one entity with multiple lease ID numbers. Supported by the Hunt family, which boasted a 12.3 percent block of LL&E stock, Caspary attacked LL&E's record since the mid-1970s, pointing to declining earnings, reduced dividends, falling reserves, and the copper acquisition. Not satisfied? Sec. At that time, the lodge housed the Louisiana Land and Exploration Companys crew while they constructed a levee around the 3,000 acre property.
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