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The Application Of Depletion To Geothermal Resources, Stephen A. Million Jan 1976

The Application Of Depletion To Geothermal Resources, Stephen A. Million

University of Michigan Journal of Law Reform

The energy crisis and the increasing costs of conventional sources of energy have created increased interest in geothermal resources as an alternative energy source. One impediment to the development of geothermal resources is the uncertainty of their status under federal tax law. This note analyzes the application of the depletion provisions of the Internal Revenue Code of 1954 to geothermal resources. Consideration is given to whether geothermal resources are exhaustible, whether they can or should be viewed as heat, and whether heat is a natural deposit or a mineral. Since geothermal resources exist in several forms, and since the depletion …


Reflections On The Tax Reform Act Of 1976, Stanley S. Surrey Jan 1976

Reflections On The Tax Reform Act Of 1976, Stanley S. Surrey

Cleveland State Law Review

What should be said in concluding these reflections on the 1976 Tax Reform Act? Overall the verdict must be on the plus side. The Act does achieve reforms in a number of areas and the serious setbacks are relatively few. The credit goes to the reform groups on the Tax Committees and in the Congress, the Budget Committees and the Congressional Budget Office, the Joint Committee Staff, the few public interest groups, the dogged efforts of a few tax reform-minded Representatives and Senators, and in ways not really fully fathomable, to the efforts, differently pursued, of Chairman Ullman and Chairman …