Table Of Content

AUTHOR INDEX [References are to pages.] A Crawford, Robert G. Determining Wellhead Value for Tax Pur- Atamian, Rubik poses ... 2-81 Privatization of the Federal Tax Audit: The Impact on the Oil and Gas Industry of Crosser, Rick L. Extending the Attest Function to Public Partnership Profit Interest Received for Ser- Companies .. . 365 vices: A Review of the Ramifications Pee fi, B Crumbley, D. Larry Buck, Everett R. Applying the Section 1031 Regulations to Oil and Gas Operations .. . 251 Tax Deferral Flame-Out on Producer Gas Imbalances ee Fifth Circuit Allows Shell to Select Their Own Allocation Base for Windfall Profit ¢ Tax Purposes . 1-51 Where Have All the Barrels Gone for Net Carter, C. P. Profit Interest Owners? .. . 2-31 Pictures of the Oil and Gas Industry: Out of Yes Virginia, An Oil-Import Fee Has Disad- Focus? ... 2-155 vantages ... 475 Charnas, Douglas W. Curatola, Anthony P. Utilizing the Alcohol Fuels Credit The Effect on Final Regualtions Governing 2-95 401 (k) Plans on Partnerships, Partners and Their Employees . . . 2-127 Chavis, Betty Voluntary Disclosure of Private, Nonpropri- D etary Information by Selected Oil and Gas Firms: An Empirical Test of Analytical Principal/Agent Models . 1-133 Davis, Alan B. Practical Guidelines for Accountants in Ana- Coker, Dianna R. lyzing Judicial Tax Law .. . 297 Where Have All the Barrels Gone for Net Profit Interest Owners? .. . 2-31 E Conover, James A. The Effect of Foreign Currency Translation Echevarria, David P. Standards on Management Actions of U. Pictures of the Oil and Gas Industry: Out of S. Oil and Gas MNCs .. . 2-137 Focus? ... 2-155 Conover, Teresa L. Eicher, Jeffrey D. The Effect of Foreign Currency Translation Oil and Gas Royalties: An Argument for Standards on Management Actions of U.S. Characterization as Non-Self-Employment Oil and Gas MNCs .. . 2-137 Income for Taxpayers in the Industry Cornia, Gary C. es oe Determining Wellhead Value for Tax Pur- Elmendorf, Richard poses ... 2-81 Voluntary Disclosure of Private, Nonpropri- Cozart, Larry A. etary Information by Selected Oil and Gas Anatomy of Foreign Tax Credits for U.S. Firms: An Empirical Test of Analytical Companies . 1-89 Principal/Agent Models . 1-133 [A-1 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520) Oil & Gas Tax Quarterl [References are to pages.] F Hitt, Leon Oil and Gas Royalties:.A n Argument for Fay, Jack R. Characterization as Non-Self-Employment Income for Taxpayers in the Industry A Comparison of Corporation Income Taxes re From A to Z (Antigua to Zimbabwe) ..~ 2-109 Hollrah, Russell A Shell’s Allocation Methods for Establishing Fenton, Jr., Edmund D. Taxable Income from Its Property Royalty Owners and Retailers in Code Sec- 2-1 tion 613A ... 417 Supreme Court Defines Basis for AMT: Wil- Howe, Thomas S. liam F. Hill Overturned . . . 463 Additional Evidence of the Impact of the ITC in the Oil and Gas Extraction Industry Forgione, Dana A. <n Fifth Circuit Allows Shell to Select Their Own Allocation Base for Windfall Profit Tax Purposes . 1-51 Joy, David W. Frazier, Kyle C. Anatomy of Foreign Tax Credits for U.S. More About an ESOP Companies . 1-89 G K Gangul, Gouranga Kim, Joseph E. Privatization of the Federal Tax Audit: The The Presence of Industry Effect in the Oil Industry Stock Return-Generating Process Impact on the Oil and Gas Industry of ... 1-161 Extending the Attest Function to Public Companies .. . 365 Koester, Robert J. Analyzing the Reserve Quantity Disclosures Gennes, Bryan L. of Oil and Gas Producing Companies The Effect on Final Regulations Governing re 401(k) Plans on Partnerships, Partners, and Their Employees .. . 2-127 L Glover, Hubert D. Larkins, Ernest R. The Effect of Public Awareness and Increas- Practical Guidelines for Accountants in Ana- ing Prices on Oil Companies’ Discretion- lyzing Judicial Tax Law .. . 297 ary Accruals . 1-145 Laufer, Doug Gramlich, Jeffrey D. Partnership Profit Interest Received for Ser- Depletion Under ACE: Ambiguity and the vices: A Review of the Ramifications Potential Impact of William F. Hill Serer ee 1 237 Licata, Michael P. H Tax Implications of Discontinuing Business Activities on an Oil and Gas Property:— What Constitutes an Abandonment? Hagan, Joseph M. .. . 495 Congressional and Judicial Attacks on Merg- ers and Acquisitions .. . 447 Luehlfing, Michael S. Appropriateness of Gain Recognition on the Hale, Mechelle A. Sale of a Business or Operating Assets to Impact of Passive Loss Rules on Working a Highly Leverage Entity—A Very Tax- Interest Owners .. . 213 ing Issue ... 1-119 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520) [A-3 Author Index [References are to pages.] Luehlfing, Michael S.—Cont. O Congressional and Judicial Attacks on Merg- ers and Acquisitions . 447 Oden, Debra H. The Potential for Use of Expert Systems in Lynch, Jr., Howell J. Oil and Gas Tax Accounting .. . 387 Commissioner Hoist on Petard of Regulatory Okopny, D. Robert Sloth: Fifth Circuit Affirmation of Tax Performance Evaluation of International Oil Court in Transco Exploration . . 1-109 and Gas Operations: Measure of the Con- trol Structure .. . 503 M Oxner, Thomas H. Mackie, James J. How Large Should the Internal Audit De- An Analysis of the Application of the Profit- partment Be in the Oil and Gas Industry? . 1-177 ability Standard at the Partnership Level for Investor-Partners: The Krause Case P seo AD Malone, David Pope, Ralph A. Voluntary Disclosure of Private, Nonpropri- Additional Evidence of the Impact of the etary Information by Selected Oil and Gas ITC in the Oil and Gas Extraction Industry tere = Firms: An Empirical Test of Analytical Principal/Agent Models . 1-133 Putman, Karl B. Economic Trends in the Oil and Gas Industry Mark, Richard S. and Oil and Gas Taxation . . . 345 Applying the Section 1031 Regulations to Oil and Gas Operations .. . 251 R McDuffie, R. Steve Reese, Craig E. The Potential for Use of Expert Systems in Privatization of the Federal Tax Audit: The Oil and Gas Tax Accounting . . . 387 Impact on the Oil and Gas Industry of Meanor, Jr., Frank Extending the Attest Function to Public Companies .. . 365 An Analysis of the Application of the Profit- ability Standard at the Partnership Level Robison, Jack for Investor-Partners: The Krause Case Applying the Section 1031 Regulations to .. . 485 Oil and Gas Operations .. . 251 N S Nemirow, Laurence E. Segal Mark A. Income Tax Aspects of In-Kind Loans Captive Insurance: Recent Cases Suggest the . 1-1 Dawning of a New Day .. . 513 Seida, Jim A. Nichols, Linda M. Proposed Regulations Give Passive “Activi- Impact of Passive Loss Rules on Working ty” a Flexible Definition . . . 223 Interest Owners .. . 213 Tax Treatment of Contested Take-or-Pay Nixon, Clair J. Liabilities: Only Amounts Actually Paid Are Deductible .. . 431 Valuation of Stock in Closely Held Oil and Gas Firms . 1-27 Sharp, Andrew D. Valuation of Stock in Closely Held Oil and The Relationship Between Airline Ticket Gas Firms, Part2 .. . 2-41 Prices and Aircraft Fuel Costs . . 537 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520) Smi Oil & Gas Tax uarterl [References are to pages.] Smith, L. Murphy Ww Oil and Gas Firms Can Support Higher Edu- cation by Offering Faculty Internships Wacker, Raymond F. ... 2-169 The In-Place Valuation of Oil and Gas Re- The Potential for Use of Expert Systems in serves Under the Alternate Valuation of Oil and Gas Tax Accounting .. . 387 Estate Property Method: The Tenth Cir- cuit Invalidates Rev. Rul. 71-317 in the Stravens, Teresa M. Estate of Holl Case .. . 285 Royalty Owners and Retailers in Code Sec- Watson, Mark T. tion 613A ... 417 Valuation of Stock in Closely Held Oil and Summers, Scott L. Gas Firms ~ eee The Effect of Public Awareness and Increas- Valuation of Stock in Closely Held Oil and ing Prices on Oil Companies’ Discretion- Gas Firms, Part2 .. . 2-41 ary Accruals ... 145 Williams, Joanne An Analysis of the Application of the Profit- V ability Standard at the Partnership Level for Investor-Partners: The Krause Case Verreault, Kathryn M. 23 2 480 Pictures of the Oil and Gas Industry: Out of Focus? ... 2-155 Z Zlatkovich, Charles P. Economic Trends in the Oil and Gas Industry and Oil and Gas Taxation .. . 345 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520) [References are to pages.] SUBJECT INDEX A Captive Insurance Company Deductibility of premiums ae Abandonment of Business Corporate Income Taxes Tax implications . 495 International tax rates . 109-126 Accrual of Income Income recognition for tax... 441 D Adjusted Basis Depletable Property Natural resource property . 468 Allocation methods Pa) Adjusted Current Earnings Development Costs Method of depletion . . . 237, 239 Code Section 613(a) ... 2-1, 2-7 Agency Theory E Principal/agent model . 1-133 Alcohol Fuels Tax Credit Economic Value Utilizing .. . 2-95, 2-108 Wellhead valuation . 2-82 Allocation Methods Elections Shell Oil Co. Case .. . 2-1, 210 Alternative valuation method . . 285,286 Taxable income from properties Employee stock option plan 2-8, 2-9, 2-12, 2-19 General requirements . . . 2-67 to 2-75 Alternative Minimum Tax Estate Taxation Overview . 238 Alternative valuation method . . 285, 286 Passive loss rules . 220 Percentage depletion . 466 Exchanges Tangible drilling and development costs Like-kind ... 251 . . . 463, 465 Excise Taxes Tax preference .. . 463,466 Gasoline .. . 2-95 Alternative Valuation Method Reduction of gasoline tax Election . 286 Expert Systems Estate taxation .. . 285, 286 Oil and gas tax accounting Audit Exploration costs Efficient size of internal audit department Full cost .. . 2-1, 2-14, 321 . 1-77 Successful effects .. . 2-1, 2-14, 320 Treatment of . 2-1, 2-7, 2-13, 2-19, C 2-26 Capital Markets F Arbitrage price theory . 1-161 Capital asset pricing model . 1-161 Fair Market Value Industry effect . 1-161 Oil and gas reserves . . . 285, 288 [S-1 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520) For Oil & Gas Tax Quarterl [References are to pages.] Foreign Currrency Translation N Foreign currency loans .. . 1-4 SFAS ... 2-137 Net Profits Interest Defined ... 2-31 Foreign Tax Credit Depletion computation . . 2-31, 2-36, 2-38 Limitation ... 1-97 Percentage depletion . . . 417, 419 Qualifying taxes . 1-90 Treatment of foreign oil related activites O . 1-94 Full Cost Method Oil-Import Fee Exploration costs .. . 2-1, 2-14, 321 Future legislation . 475 Oil and Gas Reserves G Disclosure of .. . 319 Methods of analyzing Gas Blancing Agreement Structure of . . . 203 Original Issue Discount Tax accounting . 204 Loans . 1-19 Goodwill P Defined .. 2-41 Valuation . . . 2-41, 2-43 Partnership Interest Received for services I Passive Activity Rules International Taxation Activity defined » eee International corporate tax rates . . 2-109 Alternative mininmum tax i soe to 2-126 Appropriate economic unit ee Overview ... 213 Intangible Drilling Cost Portfolio income .. . 2-61 Allocation base .. . 2-21, 2-28 Royalty income .. . 2-26 Defined . 464 Working interest owners $tng e, AES, Treatment for windfall profits tax . . 2-53 216, 485 Investment Tax Credit Percentage Depletion Economic impact . 325 Alternative minimum tax Calculation .. . 2-35 J Code Section 613(c) Entitlement . . . 2-34 Judicial Tax Law Analyzing ... In-kind loans .. . 1-15 Net profit interest owners ee a L 2-38 Like-kind Exchanges Performance Evaluation Criteria . . . 252 Entity’s control structure Multiple assets . 254 Portfolio Income Oil and gas operations .. . 251 Passive activities . 2-61 Unitization ... 266 Treatment of royalties . 2-59 Loans Producers Gas Imbalances Discharge of debt Tax accounting ... 203 In-kind ... 1-1 Original Issue discount Production Contracts Short sale ... 1-10 Take-or-pay contracts ... 1-4, 431 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520) IS-3 Subject Index Wor (References are to pages.] Property Sales Tax Accounting Highly leveraged entity .. . 2-119 Annual balancing method . 207 Cumulative balancing method . 207 R Expert systems .. . 389 Producer gas inbalances . . 203 Regression Analysis Tax Preference Internal audit department size Alternative minimum tax . . . 463, 466 Stock returns of oil industry Royalties U Interest defined +.3 2 Oil and gas . . 2-59, 2-65 Unitization Passive activities aia ee Like-kind exchanges Self-employment tax ... 2-59, 2-61 V S Valuation of Stock Self-Employment Tax Book value method . 1-46 Closey held corporation . 1-27 Treatment of royalties .. . 2-59, 2-61 Comparative analysis method . 1-31 Section 401(k) Plans Dividend capitalization method . 1-43 Affect on partnerships .. . 2-127 Earnings capitilization method . 1-39 Hardship distributions . . . 2-131 Voluntary Disclosure Staff accounting bulletin SAB No. 81 1-119 Nonproprietary information . 1-133 Successful Efforts Methods Ww Accounting for exploration costs . . 2-1, 2-14, 320 Windfall Profit Tax Alcohol fuels credit . 2-96 T Allocation base . 1-51 Allocation method .. . 2-2, 2-14, 2-19 Take-or-Pay Contracts Earnings management . 1-145 Defined .. . 431, 432 Lease bonus payments ... FIB Production contracts . 1-4, 431 Working Interest Owners Taxation of ... 433 Defined ... 2-60 Tangible Drilling and Development Costs Passive activity rules .«~. £61, 25, 216, Alternative minimum tax .. . 463, 465 485 (Matthew Bender & Co., Inc.) (Vol. 42, No. 1-9/93 Pub.520)