I
104TH CONGRESS
1ST SESSION
H. R. 2315
To amend the Internal Revenue Code of 1986 to repeal certain tax subsidies
related to energy and natural resources.
IN THE HOUSE OF REPRESENTATIVES
SEPTEMBER 12, 1995
Mr. STARK introduced the following bill; which was referred to the Committee
on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 to repeal
certain tax subsidies related to energy and natural resources.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ‘‘Termination of Energy
and Natural Resource Tax Subsidies Act of 1995’’.
SEC. 2. REPEAL OF EXPENSING OF INTANGIBLE DRILLING
AND DEVELOPMENT COSTS AND OF MINING
EXPLORATION AND DEVELOPMENT COSTS.
(a) INTANGIBLE
DRILLING
AND
DEVELOPMENT
COSTS.—Section 263(c) of the Internal Revenue Code of
1986 is hereby repealed.
(b) DEVELOPMENT EXPENDITURES.—Section 616 of
the Internal Revenue Code of 1986 (relating to develop-
ment expenditures) is hereby repealed.
(c) EXPLORATION EXPENDITURES.—Subsection (i)
of section 617 of such Code is amended to read as follows:
‘‘(i) TERMINATION.—No deduction shall be allowed
under this section for any expenditure paid or incurred
in a taxable year beginning after the date of the enactment
of this subsection.’’
(d) CONFORMING AMENDMENTS.—
(1) Paragraph (2) of section 56(a) of such Code
is hereby repealed.
(2) Subsection (a) of section 57 of such Code
is amended by striking paragraph (2).
(3) Paragraph (2) of section 59(e) of such Code
is amended by adding ‘‘and’’ at the end of subpara-
graph (A), by striking the period at the end of sub-
paragraph (B) and inserting a period, and by strik-
ing subparagraphs (C), (D), and (E).
(4) Subparagraph (A) of section 59(e)(5) of
such Code is amended by inserting before the period
‘‘, as in effect before the Termination of Energy and
Natural Resource Tax Subsidies Act of 1995’’.
(5) Subsection (c) of section 193 of such Code
is amended to read as follows:
‘‘(c) APPLICATION WITH OTHER DEDUCTIONS.—No
deduction shall be allowed under subsection (a) with re-
spect to any expenditure with respect to which a deduction
is allowed or allowable to the taxpayer under any other
provision of this chapter.’’
(6) Paragraph (1) of section 263(a) of such
Code is amended by striking subparagraph (A) and
by redesignating the succeeding subparagraphs ac-
cordingly.
(7) Section 263 of such Code is amended by
striking subsection (i).
(8) Subsection (c) of section 263A of such Code
is amended by striking paragraph (3) and by redes-
ignating the succeeding paragraphs accordingly.
(9) Paragraph (5) of section 263A(c) of such
Code, as redesignated by paragraph (8), is amended
by striking ‘‘subparagraphs (B), (C), (D), and (E)’’
and inserting ‘‘subparagraph (B)’’.
(10) Section 291 of such Code is amended by
striking subsection (b).
(11) Subsection (n) of section 312 of such Code
is amended by striking paragraph (2).
(12) Clause (i) of section 1254(a)(1)(A) of such
Code is amended—
(A) by inserting ‘‘(as in effect before the
Termination of Energy and Natural Resource
Tax Subsidies Act of 1995)’’ after ‘‘617’’, and
(B) by adding at the end the following:
‘‘For purposes of clause (i), any deduction
under section 291(b)(2) (as in effect before the
Termination of Energy and Natural Resource
Tax Subsidies Act of 1995) shall be treated as
a deduction allowable under section 263, 616,
or 617 (whichever is appropriate).’’
(e) EFFECTIVE DATE.—The amendments made by
this section shall apply to amounts paid or incurred in tax-
able years beginning after the date of the enactment of
this Act.
SEC. 3. REPEAL OF PERCENTAGE DEPLETION.
(a) IN GENERAL.—Section 613 of the Internal Reve-
nue Code of 1986 (relating to limitations on percentage
depletion in case of oil and gas wells) is amended by add-
ing at the end the following new subsection:
‘‘(f) TERMINATION.—The allowance under section
611 shall be determined without regard to this section for
taxable years beginning after the date of the enactment
of this subsection.’’
(b) TERMINATION OF SECTION 613A.—Section 613A
of such Code is amended by adding at the end the follow-
ing new subsection:
‘‘(f) TERMINATION.—The allowance under section
611 shall be determined without regard to this section for
taxable years beginning after the date of the enactment
of this subsection.’’
SEC. 4. REPEAL OF EXCEPTION FROM PASSIVE LOSS RULES
FOR WORKING INTERESTS IN OIL AND GAS
PROPERTY.
(a) IN GENERAL.—Section 469(c)(3) of the Internal
Revenue Code of 1986 is hereby repealed.
(b) CONFORMING AMENDMENT.—Paragraph (4) of
section 469(c) of such Code is amended by striking ‘‘para-
graphs (2) and (3)’’ each place it appears and inserting
‘‘paragraph (2)’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
the date of the enactment of this Act.