Internal Revenue Bulletin: 2003-30
July 28, 2003
Depreciation of assets. This ruling provides guidance as to the proper asset class under Rev. Proc. 87-56, 1987-2 C.B. 674, to depreciate assets owned by a utility that are used in the business operations of the utility. Rev. Proc. 2002-9 modified and amplified.
Tertiary injectant expenses. This ruling clarifies whether only the costs of acquiring tertiary injectants are eligible for the enhanced oil recovery credit provided in section 43 of the Code or whether the costs of using tertiary injectants also are eligible for the credit.
This notice announces the Service's position regarding certain transactions involving the transfer of nonstatutory stock options to a related person in exchange for a long-term, unsecured deferred payment obligation. The notice provides that the transfer will not constitute an arm's length transaction for purposes of regulations section 1.83-7, and that the receipt of the deferred payment obligation will not result in a deferral of the recognition of income arising from the transfer.
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