Event Details
Oil and Gas Tax Partnerships
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Thursday, February 15, 2007

Presented by

Patrick A. Hennessee, Ph.D., CPA Dr

Summary

Gain Insights into Several Problem Areas for Taxpayers Involved with Oil and Gas Tax Partnerships
In this convenient two-hour audio seminar, noted oil and gas tax expert and educator, Patrick A. Hennessee, Ph.D., CPA, will analyze and provide practical insights on some of the difficult issues of oil and gas tax partnerships.  
 
Many of the complications of working with oil and gas partnerships stem from the requirement that the partnership does not compute depletion; instead, the partnership is required to provide each partner with the information that each will need to separately compute their oil and gas depletion.  This requirement is unique in federal income taxation and tends to create several difficult and unusual problems for taxpayers involved with oil and gas tax partnerships.  Much of the confusion arises from the interactions between the relevant statutes and inconsistencies of various regulations that address the issues.


This program will first cover some background material dealing with contributions of oil and gas properties and services in exchange for a partnership interest.  This will be followed by a discussion dealing with some of difficulties posed by the statute requiring the partners to separately compute oil and gas depletion.  Some of the tangent issues include maintaining capital accounts under the regulations of Sec. 704(b); required basis allocations of oil and gas properties acquired by the partnership; required basis allocations of oil and gas properties contributed to the partnership; depletion for the partners; and allocation of tax attributes stemming from the sale or exchange of oil and gas partnerships. 
 
Don't miss this important opportunity to learn from one of the country's foremost experts about these thorny issues with oil and gas tax partnerships. And, with CCH's interactive audio seminar format, you'll also be able to ask your most pressing questions directly to Dr. Hennessee.


Program Topics
Through engaging presentation, problem solving and interactive discussion, you will learn about: 
  • Contributions of oil and gas properties to a partnership in exchange for a partnership interest
    • Applications of the provisions of Code Secs. 721, 722, 723, and 704(c) 
  • Contributions of services to an oil and gas partnership in exchange for a partnership interest
    • Current rules
    • Some proposed changes (Prop. Reg. Secs. 1.83-3 and 1.721-1) 
  • Depletion Issues
    • When oil and gas properties are acquired by the partnership
      • Partnership allocations of basis of oil and gas properties
      • Partner's tax depletion deduction on oil and gas properties
      • Tax issues when the property is sold or exchanged
      • Capital account accounting issues under Code Sec. 704(b)
    • When oil and gas properties are contributed by partners in exchange for a partnership interest
      • Applying Code Sec. 704(c) to contributed properties
      • Allocation of an oil and gas properties basis to the partners
      • Capital account accounting issues under Code Sec. 704(b)


Earn CPE Credit
  • Two hours of CPE credit are available for an additional $25 each for each person wishing to receive a CPE certificate for their participation
  • Course Level:  Intermediate
  • Prerequisite: Basic knowledge of partnership taxation
  • Learn More About CCH's NASBA Registration 


Special Bonus
Along with detailed handout materials, each site registering will receive as a bonus the following publication: 


About the Speakers
 
Patrick A. Hennessee, Ph.D., CPA Dr. Hennessee has taught numerous accounting courses, including graduate-level Oil and Gas Taxation, at the University of Tulsa since 1977.  He served as Director of the School of Accounting at the University of Tulsa from 1995-1998.  Prior to his faculty appointment, he earned a bachelor's degree from the University of Oklahoma, a master's degree from Western State College of Colorado and a doctorate from North Texas State University.  He is a member of the Oklahoma Society of CPAs, the American Institute of CPAs and the Tulsa Chapter of the OSCPA, and he serves as a trustee for the OSCPA Educational Foundation.  Dr. Hennessee is noted for drawing upon his wealth of practical and technical knowledge of the oil and gas industry to present crisp, insightful classes.  Through engaging presentations, problem solving and interactive discussion, students and practitioners effectively learn about property acquisition, geological and geophysical costs, development and depreciation of properties, deal structuring, tax credits and other complex areas of oil and gas taxation.

Additional Information

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