The Depletion Allowance Revisited

Abstract

The scholarly defenders of the depletion allowance¹ have based their exoneration of this special tax privilege primarily on two economic points: (1) percentage depletion is an offset to the non-neutrality of the corporate income tax; and (2) the tax handling of the oil and gas industry is an important stimulus to exploration of new domestic oil fields; i.e. in the absence of the depletion allowance, exploration of many wildcat fields in time period t₀ would be negligible because at existing market prices in period t₀ (and expected prices in the near future) the prospects of future revenues are not sufficient to encourage profit maximizing entrepreneurs to explore these fields with existing technology. Implicit in this view is the belief that the commitment of additional resources in exploration and development of new fields in time period t₀ is in the public interest.

Natural Resources Journal, January 1970.