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SUN CO. INC. & SUBS. (CONSOL.) v. C. I. R.

No. 81-1997.

677 F.2d 294 (1982)

SUN COMPANY INC. AND SUBSIDIARIES (CONSOLIDATED), Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Third Circuit.

Decided April 16, 1982.

Attorney(s) appearing for the Case

John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, Gary R. Allen (argued), George L. Hastings, Jr., Attys., Tax Div., Dept. of Justice, Washington, D. C., for appellant.

J. W. Bullion (argued), Buford P. Berry, Emily A. Parker, Thompson & Knight, Dallas, Tex., for appellee.

Before GIBBONS, WEIS and GARTH, Circuit Judges.

OPINION OF THE COURT

GARTH, Circuit Judge.

In this appeal we are asked to decide whether the costs of drilling offshore exploratory oil and gas wells from mobile rigs are deductible in the year in which they are incurred as "intangible drilling and development costs" under 26 U.S.C. § 263(c) and Treas.Reg. § 1.612-4(a) ("the IDC option"). The Tax Court ruled in favor of the taxpayer, Sun Co., and against the Commissioner, in holding that such drilling...

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