growth rate 2000?2005, Cane River National Heritage Area near This appeal stems from the granting of a motion for partial summary judgment in favor of the Louisiana Land and Exploration Company (LL & E). Wisner was struck by swampy southern Louisiana's resemblance to the low-lying Netherlands, where industrious farmers had reclaimed millions of acres for farming. Contact Information Website lle.com Ownership The natural gas is then transported through natural gas pipelines for use by petitioner or sale to Florida Gas Transmission Co. pursuant to a long-term gas purchase contract dated November 15, 1971. For the purposes of this subsection, minerals (other than sodium chloride) extracted from brines pumped from a saline perennial lake within the United States shall not be considered minerals from an inexhaustible source. The Louisiana Land and Exploration Company LLC has 581 employees, and the revenue per employee ratio is $481,927. 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". In 1966 he acquired Jacintoport Corporation, an industrial real estate firm with Gulf Coast holdings such as the Houston Ship Channel. 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. (162m/532ft); vast coastal areas of marsh, lagoon, and 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 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. The remainder of central and north Louisiana was home processing, transportation equipment, paper products, and WebSuperior Performance Oil And Gas Exploration Service 122 Youngsville Hwy Lafayette, LA 70508 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. Visit DandB.com to locate more business profiles. 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. denied 382 U.S. 892 (1965). In the early 1970s, however, its Louisiana reserves began their natural decline. Congress also was concerned, however, with the shortage of hydrocarbon fuels and the need to encourage domestic exploration for and exploitation of new sources of fuel. These moves strengthened LL&E's overall position, but plunging oil prices and the Copper Range charge took their toll. Timken agreed and in 1926 exchanged his acres for shares in the Border Research Corporation. 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. As if to bear out this description, LL&E's mining operation lost $7.8 million in 1977 and $6.6 million in 1978. 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). Milling, Benson, Woodward, Hillyer, Pierson & Miller, Charles D. Marshall, Jr.. See: In the Matter of Amoco Production Co., 78 IBLA 93 (1983) (A decision by the Interior Board of Land Appeals with appeal currently pending in the federal district court, western district of La., docket # CV84-0916); Letter opinion by Charles A. Moore, general counsel of Federal Energy Regulatory Commission, addressed to Tipperary Corp., 1982 Federal Program Advisory Service, p. 3, para. The primary products from the Jay Field wells and processing facilities have been oil and natural gas. petroleum and "The normal royalty was one-eighth (12 percent). Rec. 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? 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. In addition, in December 1976 LL&E acquired the Warrior River Coal Company, owners of a small surface mine in Tuscaloosa, Alabama. 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. 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). Sulphur has been recovered from hydrogen sulfide and sold as a by product of the processing facilities since the facilities were placed in operation. Oil and Gas Indian Communitization Agreement, Oil and Gas Simultaneous Lease Drawing (SIMO) on Public Land, Oil and Gas Simultaneous Lease Drawing (SIMO) on Acquired Land, Oil and Gas Non-Competitive Lease on Acquired Land, Louisiana Land & Exploration Co. is listed with 11 total leases. 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. Representative William Green introduced an amendment to repeal percentage depletion for oil and gas during the floor debates in the House but the Senate Finance Committee deleted the provision. In 1974 Jacinport reported $2 million in real estate sales. "It was a very unusual contract for 1928," LL&E president Ford Graham told Dun's Review in 1965. To this end, in 1991 LL&E acquired two interests in Australia and applied for a concession in Papua New Guinea. 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). Wednesday, July 9, 1997. WebContinuing the marriages among energy companies, Burlington Resources Inc. agreed to acquire Louisiana Land & Exploration Co. for about $2.44 billion in stock. 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. Because the rules of section 613A work on the foundation of section 613, we look first to the plain language of section 613. 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. Texaco answered LL & E's petition for damages by denying that its royalty payments were improper, and subsequently filed a motion for partial summary judgment seeking a declaration that its payments were proper at least with respect to the gas it had produced from wells drilled prior to the enactment in 1978 of the Natural Gas Policy Act (NGPA), 15 U.S.C. There is no indication that Congress intended to limit percentage depletion for any products of oil and gas wells other than hydrocarbon fuels.12. 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. 7295. 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. 121 Cong. In 1955 it reported $13.4 million in profits on sales of $22.4 million. LL&E reported 1986 losses of $20.6 million. Louisiana. Respondent's position in this case thus seems to conflict with his reading of section 613A as expressed in one of his published rulings. 613A(c)(3). 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. Pursuant to section 613A, oil and gas wells qualify for percentage depletion in narrowly limited circumstances. The Drillings is a resource for locating where oil and gas leases are and have been. WebThe Louisiana Land and Exploration Company (LL&E) is one of the largest independent oil and gas exploration companies in the United States. 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. Follow fishing, particularly for shrimps and oysters; a major source of 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. In Rev. For this reason, Congress chose to define natural gas by reference to what gases are depletable pursuant to section 611. In 1930 Texaco also agreed to pay LL&E's $1.8 million funded indebtedness. Petitioners contend that section 613 and section 613A are mutually exclusive and thus whatever is depletable under section 613 is not depletable under section 613A. the first historian of Louisiana with his. The company was incorporated in 2010 and is based in New Orleans, Louisiana. The practice in the oil and gas industry when section 613A was enacted was to sell hydrocarbon gas for use as fuel under long-term fixed price contracts. WebAsbestos & Mesothelioma, Medical Malpractice, Nursing Home Abuse, Personal Injury, Products Liability, Workers' Compensation Website Email Profile John J. Lynch Chicago, IL (630) 283-7091 Bankruptcy, Probate, Foreclosure Defense, Real Estate Law, Estate Planning Website Email Profile ; Shamrock Oil & Gas Corp. v. Commissioner, 35 T.C. 4611 (1975) (remarks of Representative Green); 121 Cong. hills; over half the land area forested, supporting a major lumber Timken hoped to lease the land to fur trappers. 121 Cong. Natchez, Jean Lafitte National Historical Park and The Louisiana Land and Exploration Company LLC operates as a subsidiary of ConocoPhillips. Wisner's plans, however, were thwarted by southern Louisiana's severe weather. Section 613A(e)(1) defines "crude oil" as including "a natural gas liquid recovered from a gas well in lease separators or field facilities." Rec. These geospatial data and related maps or graphics are not legal documents and are not intended to be used as such. It soon became apparent that the land owned by Louisiana Land and Exploration, as the company was renamed in 1927, was rich in petroleum resources. WebThe Louisiana Land and Exploration Company was presented the 1997 National Association of Conservation Districts (NACD) Business Conservation Leadership Award at a luncheon In 1980 he formed CLAM Petroleum, a 50 percent owned unconsolidated affiliate through which LL&E would invest $250 million in the U.K. North Sea's South Brae Field. 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. The amine solution absorbs the hydrogen sulfide and carbon dioxide and natural gas flow out of the top of the contactor. Decisions will be entered under Rule 155. Hydrocarbons are organic compounds containing only hydrogen and carbon and are most commonly used as fuels. Management trumped Caspary, however, when it pledged to spin off to stockholders a tax-sheltered royalty trust holding oil and gas properties that generated $30 million a year. These apparent anomalies are reconciled, in respondent's view, by attributing to Congress an unexpressed intent to deny any percentage depletion for nonhydrocarbon gases. These diversification adventures were possible in part because of high profits in the oil industry. The venture's finances faltered and in time there were foreclosures. The company's troubles climaxed the following year as investor Delo Caspary mounted a proxy fight to remove Phillips and the rest of management. Construction began on a new catalytic reformer that would provide more highly valued refined products. The acid gases (hydrogen sulfide and carbon dioxide) are separated from the natural gas through an absorption process. 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. 1763, then to the USA in 1783; W region acquired by the USA in the The terms of stipulations are generally binding on the parties and the Court will not allow a party to ignore a stipulation except "where justice requires." He added, however, "we are now talking about onepetroleumwhich is the most important of all energy items at this time." 94-36, 94th Cong., 1st Sess. 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. around New Orleans; special population groups of Creoles (French It replaced 203 percent of expended reserves, adding 55 million equivalent barrels of oil and natural gas, 46 percent of which came from the East Brae Field. 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. Terms of Use, Ultra Petroleum Corporation Business Information, Profile, and History, The Columbia Gas System, Inc. Business Information, Profile, and History, *Estimated as of July 1, 2005U.S. Sec. 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. (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. 4606 (1975). 1965), cert. 1971). Sec. WebLa. As the largest owner of environmentally sensitive wetlands in the continental United States, LL&E had long been careful to protect its investment. In 1984 Phillips was replaced by E. L. Williamson, who worked to sustain profit margins and increase reserves. LL&E continued to do quite well in the late 1960s and early 1970s, reporting income of $51.9 million on 1970 sales of $114 million. Not satisfied? As LL&E operations grew, both sales and revenues increased. Natural hazards may or may not be depicted on the data and maps, and land users should exercise due caution. 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 In these consolidated cases, the Commissioner determined deficiencies in petitioners' Federal corporate income tax for the taxable years 1979, 1981, and 1982 as follows: The sole issue remaining for our decision is whether petitioners are entitled to percentage depletion pursuant to section 6131 on income from sulphur chemically converted from hydrogen sulfide produced from an oil and gas well. We agree with the district court that Section 109 applies. 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. By year's end, Phillips could boast of $94 million in profits on sales of $1.25 billion. 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. Petitioners, the Louisiana Land & Exploration Co. (LL&E) and Subsidiaries, are an affiliated group of corporations whose common parent is LL&E. and its Licensors 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. It was solely Texaco's choice to meet its obligations to these customers with LL & E's gas. Learn more about the Bureau of Land Management, Public Land Survey System, and oil and gas leases. The Louisiana Land and Exploration Company LLC operates as a subsidiary of ConocoPhillips. 123673km/47752sqmi. State in S USA, Lease No. Section 613(b) in general provides the list of minerals that are eligible for percentage depletion and specifies the percentage depletion rates. While this revenue ruling does not squarely set forth respondent's position on the facts of this case because in the ruling the carbon dioxide was not produced from an oil and gas well, the ruling directly states respondent's reading of section 613A as applying only to hydrocarbon fuels and of section 613(b)(7) as applying only to minerals not expressly provided for elsewhere in subsection (b). 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.". 121 Cong. Phillips Petroleum Co. Poydras Energy Partners, LLC Shoreline Southeast LLC Tenneco Inc. Texaco, Inc. Union Pacific Resources Co. Drilling wells, permits, operators and production information can give you an Pub. Phillips, however, remained committed to Copper Range. Congress responded to this public outcry by repealing the percentage depletion allowance as applied to the major integrated oil companies.". The diagram on the facing page summarizes the sour production processing system used at the Jay Field Wells. In 1984, large additions and renovations were made to the lodge, increasing the size of the camp to accommodate more guests. The separated natural gas is processed further in another contactor which removes water vapor from the gas stream. Finally, respondent's interpretation of section 613A conflicts with normal usage of the term "natural gas" as meaning fuel.
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