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Congress did not intend to take any tax benefit away from independent producers in approving section 613A. Crude oil is measured and sold by barrels. The court found that because of the flexibility of the warranty contracts, even though the gas may have been economically committed to these customers, it was not "subject to" any contract, and therefore was governed by Section 109 rather than Section 105. percent. In 1975 the company opened a small refinery in Mobile, Alabama, to process 30,000 barrels a day of Jay Field crude. 17-023-20688: Well Direction: Operator: MCMORAN EXPLORATION COMPANY: Lease No. Wednesday, July 9, 1997. THE LOUISIANA LAND AND EXPLORATION COMPANY AND SUBSIDIARIES, PETITIONERS The Island is also the original home of Spots, the beloved blue-eyed white alligator who lived at the Audubon Aquarium of the Americas for 24 years. 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. After processing, the crude oil is classified as sweet rather than sour oil. Its price is not regulated by the Federal Power Commission. Louisiana Land & Exploration Co/The - Company Profile Pierre-Franois-Xavier de Charlevoix, Dumont (as published The company was incorporated in 2010 and is based in New Orleans, Louisiana. The taxpayer may elect to convert part of his oil quantity into a depletable natural gas quantity based on a conversion ratio of 6,000 cubic feet of gas to one barrel of oil. The Drillings makes no warranty, expressed or implied, including the warranties of merchantability and fitness for a particular purpose, nor assumes any legal liability or responsibility for the accuracy, reliability, completeness or utility of these geospatial data, or for the improper or incorrect use of these geospatial data. WebHistorical stocks and bonds, Autographs, Americana, Ephemera, Numismatics and all forms of paper collectibles specializing in Uncancelled bonds Since then, the area around Paradis has attracted generations of hunting and outdoor enthusiasts alike. 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. By 1970, an oversupply of sulphur seriously depressed prices,4 but the sulphur market recovered and the price of sulphur rose dramatically in the late 1970's and early 1980's.5. Natural hazards may or may not be depicted on the data and maps, and land users should exercise due caution. Phillips, however, remained committed to Copper Range. 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. 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. Respondent argues that the two provisions are interdependent in that section 613A(e)(2) defines natural gas in terms of products depletable under section 611 and section 613, and in enacting section 613A and amending section 613, Congress intended to transfer percentage depletion for all products of oil and gas wells to section 613A. The oil stabilization system also reduces the vapor pressure of the crude oil to a low enough level that it can be stored and transported in atmospheric tanks and tank trucks. Lease No. In no case shall the allowance for depletion under section 611 be less than it would be if computed without reference to this section. (b) EXEMPTION FOR CERTAIN DOMESTIC GAS WELLS.. 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. originally applied to the entire Mississippi R basin, claimed for In 1928 LL&E signed a contract with Texas Co. (now Texaco) in which that company agreed to lease all of LL&E's acreage around ten productive salt domes. Small producers must also separate hydrogen sulfide from natural gas before the natural gas may be transported through pipelines and used as fuel. The property has been operated as a hunting lodge since the 1960s. Hydrogen sulfide, alone, or in combination with natural gas is also unsuitable for use as a fuel because the combustion of hydrogen sulfide produces sulphur dioxide, a toxic substance subject to control under Federal pollution standards. Until 1982, the Frasch mining industry was the dominant source of sulphur in the world. United States v. American Trucking Association, 310 U.S. 534, 543 (1940). 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 on the history of New Orleans (q.v. Texaco released the fee lands belonging to the company not located on or near the domes or structures which were then being operated by Texaco. be cited: Jean-Bernard Bossu, Franois-Marie Perrin du Lac, 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. These moves strengthened LL&E's overall position, but plunging oil prices and the Copper Range charge took their toll. plants in several cities; leads the nation in salt and sulphur Caspary's charges had some legitimacy. We agree with the district court that Section 109 applies. 123673km/47752sqmi. Thus, respondent's proposed statutory construction, which assumes an inadvertent failure by Congress to draft the right language, cannot be harmonized with the provision for depleting sulphur pursuant to section 613(b)(1). Louisiana Land and Exploration Co Listed below are those cases in which this Featured Case is cited. 204(c)(2), 44 Stat. 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. History Timeline 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). Department of Natural Resources | State of Louisiana Hydrogen sulfide is a poisonous, highly corrosive gas which cannot be vented into the atmosphere in large quantities without serious deleterious effects. Specifically, subparagraph (C) does not state "minerals from oil and gas wells.". The Louisiana Supreme Court has already held that the value of natural gas upon which royalty is owed may not exceed the price to which sale of that gas is limited by federal regulation. 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 In 1980, LL E earned profits of 180.2 million dollars or $4.74 per share. 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. The sour gas streams from the separation system and the oil stabilization system, containing both natural gas and hydrogen sulfide, are combined and further treated in the acid gas removal system. 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. The extent of the damages, if any, suffered by LL & E must be determined in a further proceeding. The well effluent from the Jay Field wells is treated in facilities adjacent to the wells. 121 Cong. Follow Mexico; rivers include the Mississippi (large delta area in the S), The data are dynamic and may change over time. During the 1960s, CEO Fred Graham began a process of diversification that would eventually include a Hawaiian resort, a coastal industrial real estate operation, and coal, gold, and copper mines. 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. Rec. H. Leighton Steward, Chairman of the Board of The Louisiana Land and Exploration Company, and Terry Ryder, Special Counsel for Governor Murphy J. Click the citation to see the full text of the cited case. Rec. As the company expanded into working interests, it hired geologists, geophysicists, and engineers. Respondent's stipulation also suggests that the amount of the depletion deduction is susceptible of calculation. 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. 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. 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. 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. There are generally two types of marketing contracts for the sale of gas. descent) and Cajuns (descendants of French Acadians driven from 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). increasing; world famous for the jazz music which grew up in and 979 (1961), affd. v. (e) DEFINITIONS.For purposes of this section. 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. Pub. 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. 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. La Land It was solely Texaco's choice to meet its obligations to these customers with LL & E's gas. 4606 (1975). Envisioning farming on a grand scale, Wisner bought hundreds of thousands of acres, built levees, and drained the land. 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. (It is the biggest producer of crawfish in the world), cotton, soybeans, The capital stock of LL E is registered with the Securities and Exchange Commission ("SEC") and is traded on the New York Stock Exchange. 1965), cert. As if to bear out this description, LL&E's mining operation lost $7.8 million in 1977 and $6.6 million in 1978. the more important, as well as the publications of the 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. It appears that the absence of the phrase "minerals from" from paragraph (C) was not an oversight. Sec. 7807. Subparagraph (C), which states the oil and gas well exception from depletion, states simply "oil and gas wells." In 1930 Texaco also agreed to pay LL&E's $1.8 million funded indebtedness. Deteriorating economic conditions, windfall profits taxes, high dry hole costs, narrower profit margins, and declining demand all pressured earnings. After winning the proxy fight in 1983, Phillips sold LL&E's coal properties and bought back 71 million shares for $212.8 million. Rec. Land & Expl. 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. 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. Commissioner v. Engle, 464 U.S. at 218. 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). Principal Subsidiaries: CL&E Corp.; Inexco Oil Co.; Wilson Bros. Drilling Co.; Molokai California Ltd.; LLOXY Holdings, Inc.; White Pine Leasing, Inc.; LL&E Properties, Inc.; Westport Utilities Systems Co., Inc.; LL&E (Netherlands) Inc.; CLAM Petroleum Co.; MaraLou Netherlands Partnership (50%). Thus, it falls in the category of all other minerals described in section 613(b)(7) and is eligible for percentage depletion at the rate of 14 percent. The brine water is reinjected into the well. As a result, LL&E enjoyed low expenses and high profits. 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 94-36, 94th Cong., 1st Sess. WebLouisiana Land & Exploration Co/The - Company Profile and News - Bloomberg Markets Bloomberg Anywhere Remote Login Manage Products and Account Information Indices Louisiana. LOUISIANA LAND Under respondent's reading of section 613A(e)(2), section 613A provides exemptions for hydrocarbons extracted by independent producers and royalty owners but eliminates percentage depletion of nonhydrocarbon "natural gases" extracted from oil and gas wells for all taxpayers. In February 1943, President E. B. Tracy signed a contract with Duval Texas Sulfur Co. that gave that company sulfur exploration, development, and production rights on LL&E's land and leased interests in Louisiana's Terebonne Parish. To this end, in 1991 LL&E acquired two interests in Australia and applied for a concession in Papua New Guinea. 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. Box 60350 New Orleans, Louisiana 70160 U.S.A. (800) 351-1242 Fax: (504) 566-6891 Public Company Section 613(b)(1)(A) provides that sulphur is depletable at a 22-percent rate. A number of travel relations by 17th and 18th century v. Louisiana Land and Exploration Co Oil and Gas Producers | Houma, LA - Manta.com Census Bureau: Population Estimates**Estimated annual 4611 (1975) (remarks of Representative Green); 121 Cong. The Louisiana Land and Exploration Company filed as a Foreign For-Profit Corporation in the State of Texas and is no longer active.This corporate entity was filed approximately eighty-four years ago on Monday, October 9, 1939 , according to public records filed with Texas Secretary of State.It is Louisiana Texaco pays 75 percent and gets 60 percent. Sec. 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." WebThe Louisiana Land And Exploration Company LLC 806 Bayoo Black Drive Houma, LA Visit Website Categorized under Oil and Gas Producers Apache Louisiana Minerals LLC 1913 La Under the agreement, LL&E retained a 25 percent working interest and a 20 percent royalty in Texaco's share of production. Business Week called Louisiana Land's record "dismal" and noted that despite spending $1.4 billion over the previous four years Phillips had failed to increase oil and gas reserves. 30:29 (referred to as Act 312), this oilfield remediation case involved the Vermilion Parish School Board (VPSB), individually and on 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. The venture's finances faltered and in time there were foreclosures. We disagree. Sec. 613A(c)(3). During the 1950s, CEO Robert M. Youngs began investing in working interest wells. LOUISIANA LAND AND EXPLORATION COMPANY Graham worked hard to keep expenses down. 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." Hydrogen sulfide is never used as a fuel and is not sold under long-term fixed price contracts. Section 613A was the product of congressional concerns about the nation's increasing dependence on foreign oil and large profits the major integrated oil companies were reaping. 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. Although this Court will disregard a stipulation that is plainly contrary to the facts (Jasionowski v. Commissioner, 66 T.C. 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.