Shell Oil Co. v. Commissioner’s Empirical Analysis
952 F.2d 885 · 1992
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 8 later decisions — most recently January 2020
3 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 26 U.S.C. § 7482
Relies on Dresser Industries, Inc. v. Commissioner · Shell Oil Co. v. Commissioner · Occidental Petroleum Corp. v. Commissioner
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“all allowable deductions (excluding any deduction for depletion) which are attributable to mining processes, including mining transportation, with respect to which depletion is claimed. These deductible items include operating expenses, certain selling expenses, administrative and financial overhead, depreciation, taxes deductible under section 162 or 164, losses sustained, intangible drilling and development * * * expenditures, etc. * * * Expenditures which may be attributable both to the mineral property upon which depletion is claimed and to other activities shall be properly apportioned to the mineral property and to such other activities. Furthermore, where a taxpayer has more than one mineral property, deductions which are not directly attributable to a specific mineral property shall be properly apportioned among the several properties. * * *”
1 later decision quote this exact passage · from the majority“[T]he analysis of the reasonableness, fairness or propriety of an apportionment method [for purposes of depletion] ... is a factual [inquiry] requiring a remand to the tax court for appropriate findings.”
1 later decision quote this exact passage · from the majority“intangible drilling and development costs”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.