Deteriorating economic conditions, windfall profits taxes, high dry hole costs, narrower profit margins, and declining demand all pressured earnings. The other major source of sulphur for commercial use is the Frasch sulphur mining industry. It is true that the statutory language on its face is incongruous. Respondent's position, although technically viable, is supported neither by legislative history nor by common usage of the term "natural gas." Field / Formation: GOLDEN MEADOW / THE LA LAND & EXPLORATION CO M 001: Well Status: DRY AND PLUGGED: Well Type: Township Range Section: 19S 22E 039: Derrick Elevation: Members Only: Kelly Bushing Elevation: 3301 et seq. Louisiana. 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.". See 121 Cong. Respondent raises a final argument for the first time on brief that sulphur derived from hydrogen sulfide cannot be depletable pursuant to section 613 because it is not possible to calculate "gross income from the property" with respect to the sulphur as section 613(c) requires. 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 The Louisiana Land & Exploration Co These geospatial data and related maps or graphics are not legal documents and are not intended to be used as such. These apparent anomalies are reconciled, in respondent's view, by attributing to Congress an unexpressed intent to deny any percentage depletion for nonhydrocarbon gases. Section 611(a) allows as a deduction in computing taxable income from natural resources a reasonable allowance for depletion. Its industrial outputs include chemical products, Louisiana 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. 7295. At that time, the lodge housed the Louisiana Land and Exploration Companys crew while they constructed a levee around the 3,000 acre property. 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. Prior to 1975, section 613 allowed percentage depletion for oil and gas wells. 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. "The normal royalty was one-eighth (12 percent). Phillips, meanwhile, continued to diversify. 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. (1975). Sec. (d) DENIAL OF PERCENTAGE DEPLETION IN CASE OF OIL AND GAS WELLS.Except as provided in Section 613A, in the case of any oil or gas well, the allowance for depletion shall be computed without reference to this section. 121 Cong. In addition to the Texaco royalties, which were still significant (of 25 Lake Barre Field wells Texaco completed in 1964, 21 produced oil, two produced gas and only two were dry), LL&E had signed royalty agreements with Union Oil of California, Signal Oil, Amarada Hess, and Humble Oil and Refining. 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. On this reasoning, respondent concludes that "natural gas" within the meaning of section 613A includes all gases produced from an oil and gas well because all such gases are depletable under section 611. 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. Specifically, "natural gas" subject to section 613A is defined to include "any product (other than crude oil) of an oil or gas well" if the product is eligible for depletion. 121 Cong. Rec. La Land LOUISIANA LAND AND EXPLORATION COMPANY For example, we don't hesitate to use consultants. 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. H. Leighton Steward, Chairman of the Board of The Louisiana Land and Exploration Company, and Terry Ryder, Special Counsel for Governor Murphy J. Follow Construction began on a new catalytic reformer that would provide more highly valued refined products. All the gas involved in this dispute is being used by Texaco to service warranty contracts Texaco entered into with intrastate industrial consumers prior to 1978, when the NGPA was enacted. Sulphur is mentioned once in the congressional debates as part of a list of 108 mineral extractive industries for which percentage depletion was retained. Respondent thus argues that because the sulphur in issue is a product of oil and gas wells, it loses its section 613 depletion allowance. Respondent's position in this case thus seems to conflict with his reading of section 613A as expressed in one of his published rulings. WebThe Louisiana Land and Exploration Co. (LLEC) (defendant) claimed that it was the actual owner of the land between the Liners recorded title boundary and Bayou Dufrene. processing, transportation equipment, paper products, and 613(A)(c)(4). The sales The Claus system chemically converts more than 96 percent of the hydrogen sulfide into elemental sulphur. The venture's finances faltered and in time there were foreclosures. Moreover, because of varied corporate exploration philosophies and changes in drilling and seismic forecasting techniques, LL&E was constantly leasing and re-leasing the same acreage to different operators. The Drillings is a resource for locating where oil and gas leases are and have been. Through the 1930s and 1940s, LL&E collected royalties on oil and minerals extracted from the land it owned and controlled. Nevertheless, the company budgeted $200 million for capital and exploration and continued to drill in the Gulf of Mexico, Madden Field in Wyoming, the gas-rich Anadarko Basin of Western Oklahoma, the North Sea, southeastern Alberta, and Columbia, where it was garnering positive results from a drilling program begun in 1978. by Fr. See Rev. History Timeline After reviewing the law and the facts, we find that the district court was correct in its determination. 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). A number of members criticized the provision for unfairly singling out the oil and gas industry. cattle, sugarcane, poultry and eggs, dairy products, and The well effluent is initially treated in a separation system which uses gravity to separate the effluent into brine water, sour crude oil, and a sour gas stream containing natural gas, hydrogen sulfide, and carbon dioxide. We reject LL & E's contention that it has proven by affidavit that the gas could at all times have been sold at the Section 109 ceiling price, thereby establishing its value for royalty purposes under the leases. The exemptions from the general rule of section 613A(a) denying percentage depletion for oil and gas wells, however, function only when applied to hydrocarbon fuels. In 1982 matters continued to deteriorate as a recession caused a downturn in prices for liquids, lower demand and prices for copper, a halving of refinery margins, and reduced demand for natural gas. By year's end, Phillips could boast of $94 million in profits on sales of $1.25 billion. WebThe Louisiana Land & Exploration Co is listed as an officer of another company. THE LOUISIANA LAND AND EXPLORATION COMPANY AND SUBSIDIARIES, PETITIONERS The early 1960s proved very successful for LL&E. In addition, in December 1976 LL&E acquired the Warrior River Coal Company, owners of a small surface mine in Tuscaloosa, Alabama. A number of cities in Louisiana are also home to Jewish communities, 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). percent. Pierre-Franois-Xavier de Charlevoix, Dumont (as published We find that the use of the term "subject to" in subsection (b), (and again in Section 109) necessarily qualifies the more general language "sold under". 7295. WebThe Louisiana Land and Exploration Company LLC * 5 Principals See who the company's key decision makers are 3 Contacts Reach the right people with access to detailed contact Section 613A bars percentage depletion for oil and gas wells with two exceptions. 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, 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. area, List of school districts 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). In 1984 Phillips was replaced by E. L. Williamson, who worked to sustain profit margins and increase reserves. Of the company's 225 million barrels of oil equivalent reserves, nearly 60 percent are garnered from domestic sources. In Rev. Join our mailing list to get alerts for lease listing updates, new features, and special opportunities. The amine solution absorbs the hydrogen sulfide and carbon dioxide and natural gas flow out of the top of the contactor. Wolf Exploration Company shall, as to such leases, be entitled to the same overriding royalty, provided for hereinabove in paragraphs 1.1.1 through 1.1.5. 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"). posthumous and further expanded edition in 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. Oil and Gas lease entities located near Louisiana Land & Exploration Co.. It also sought to expand riskier but potentially more lucrative foreign exploration. The user is responsible to verify the limitations of the geospatial data and to use the data accordingly. As on previous occasions, LL&E's involvement was a financial one. Products; Resources; My Account; Talk to a D&B Advisor 1-800-280-0780. Business Directory. Headquartered in New Orleans, it chief cities, New Orleans and Shreveport; bounded S by the Gulf of The nonhydrocarbon gases extracted from the Jay Field wells are primarily hydrogen sulfide and carbon dioxide. In 1943, for instance, LL&E employed only 24 people, yet earned $1.8 million on sales of $3.4 million. Timken hoped to lease the land to fur trappers. Rule 91(e), Tax Court Rules of Practice and Procedure. 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. Wisner's plans, however, were thwarted by southern Louisiana's severe weather. Finally in 2018, the camp was yet again renovated turning it into the beautiful lodge it is today. Login | Register; Home; Operators; Leases; Wells; Permits; Pricing; Search; Map; Sweet Lake Land And Oil Co 001: API No. 7295. Lease No. The conversion ratio represents a fuel equivalence; 6,000 cubic feet of natural gas generates the same amount of heat as one barrel of oil. 1.613-3(a), Income Tax Regs. Until 1982, the Frasch mining industry was the dominant source of sulphur in the world. Hydrocarbons are organic compounds containing only hydrogen and carbon and are most commonly used as fuels. Red, Sabine, and Pearl; highest point Mt Driskill v. Rightor and John Kendall Smith. Respondent interprets section 613A(e) as follows: Section 613A(e)(2) provides a definition; it is not an allowance section. 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. 121 Cong. L. 94-12, sec. One barrel of oil has the equivalent fuel value, measured in British Thermal Units (BTU's) of 6,000 standard cubic feet of natural gas.6. In 1989 the Department of Interior recognized this effort and awarded LL&E its Conservation Award for Respecting the Environment. 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. WebLL E is engaged primarily in exploration for and development of petroleum, natural gas and minerals. Moreover, because petitioners do not qualify for percentage depletion under the exemptions set forth in section 613A(b) and section 613A(c), the sulphur is also not eligible for percentage depletion under section 613A. Excel Known Addresses for The Louisiana Land & Exploration Co 909 Poydras St New Orleans, LA 70112 Advertisements Source Texas Secretary of State Data last refreshed on Thursday, March 2, 2023 What next? In 1930 Texaco also agreed to pay LL&E's $1.8 million funded indebtedness. LL & E's position is that Section 105 does not determine the ceiling price for this gas because the gas is not "subject to" any contract; instead, the LL & E gas is being used to fulfill these particular contracts solely because Texaco has chosen to use it rather than to use gas from other reserves. Caspary's charges had some legitimacy. The company had few employees and operators shouldered the major expenses of exploration and development. Both are part of the PLSS measurement system but have different uses. Sec. WebLouisiana Land & Exploration Co/The - Company Profile and News - Bloomberg Markets Bloomberg Anywhere Remote Login Manage Products and Account Information Indices (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. (a) GENERAL RULE.In the case of the mines, wells, and other natural deposits listed in subsection (b), the allowance, for depletion under section 611 shall be the percentage, specified in subsection (b), of the gross income from the property excluding from such gross income an amount equal to any rents or royalties paid or incurred by the taxpayer in respect of the property. This professionalism is the result of corporate leadership, teamwork, open communications, customer/supplier partnership, and state-of-the-art manufacturing. Founded as the Border Research company in 1926 and renamed Louisiana Land and Exploration a year later, LL&E, for its first twenty years, essentially collected royalties from fossil fuels extracted from nearly 600,000 acres it controlled in southern Louisiana. Contact Information Website lle.com Ownership Webster's Third New International Dictionary 1507 (1981) defines natural gas in terms of its value as a fuel: any of various combustible gas mixtures that when in the dry state contain largely methane and in the wet state in association with petroleum contain also higher hydrocarbons and that are used chiefly as fuels * * *. As the company expanded into working interests, it hired geologists, geophysicists, and engineers. 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. Second, percentage depletion is permitted for so much of a taxpayer's "average daily production" of domestic crude oil or natural gas as does not exceed the taxpayer's "depletable oil quantity" or "depletable natural gas quantity." (various editions, culminating in 1866, 4 vols., with a fishing, particularly for shrimps and oysters; a major source of We disagree. Seeking new profit sources and seeing links between fossil fuels and mineral extraction, Phillips laid out $51 million for the Copper Range Company in May 1977. 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. Petitioners claimed percentage depletion on sulphur during the years in issue in the following amounts: Respondent issued his notices of deficiency and petitioners timely filed petitions on the following dates: If we find that petitioners' sulphur production is eligible for depletion under section 613(b), respondent concedes that petitioners are entitled to the percentage depletion deductions claimed. We find that it was appropriate, and therefore affirm the ruling of the district court. St. Bernard Parish, Baritaria (Crown Point), and Acadiana Although it did not expressly hold that "oil and gas wells" means "oil and gas," the Court referred repeatedly to oil and gas production, not the production of minerals from oil and gas wells. increasing; world famous for the jazz music which grew up in and Respondent has stipulated that if we find petitioners are entitled to percentage depletion deductions, they correctly computed the amount of the depletion deductions on their Federal income tax returns. With no more than 4.4 years of proven reserves on hand in 1980, Phillips needed to find new reserves at a reasonable cost if he was to insure the company's continued profitability. 613A(c)(3). 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). The goal of the legislation was to eliminate what was perceived to be an unneeded tax incentive only for the major integrated oil companies. 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. Louisiana land & exploration company Company Profile: The main lodge located at The Island was built entirely from cypress logged and timbered from the Des Allemands area. Graham worked hard to keep expenses down. Natural gas is measured and sold by standard cubic feet. 4611 (1975) (remarks of Representative Green); 121 Cong. But while business was very good in the late 1970s there were doubts about LL&E's future.
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