The Use of Special Allocations in IDC in Oil and Gas Partnerships
Patrick Hennessee, David Armstrong, and David Weber
The authors review the intent of Internal Revenue Section 704, the related existing Regulations, and the Proposed Regulations under Sec. 704(b) issued in March 1983. The authors then summarize case law relating to the allocation problem, concluding that the Proposed Regulations may clarify some controversies but will create controversies in other areas.
The Use of Special Allocations in IDC in Oil and Gas Partnerships. Hennessee, Patrick; Armstrong, David; and Weber, David, Fall/Winter 1983, pp. 85‑96.