Federal Tax Day - Current, L.5, Code Sec. 614: Consent Granted to Aggregate Separate Nonoperating Mineral Interest (LTR 202624005), (Jun 15, 2026)

A corporation was granted consent to aggregate the separate nonoperating mineral interests with respect to separate properties, such that each of the separate properties were treated as one property. The taxpayer used to acquire mineral, oil and natural gas royalties, and other nonoperating mineral interests worldwide. Moreover, no cost depletion deductions in excess of those to which taxpayer would otherwise be entitled in the absence of such aggregations were expected to result from the requested aggregations of the separate interests. The taxpayer fulfilled the requirements of Reg. §1.614-5 in respect of both interests. Therefore, granting relief did not prejudice the government's interests.

IRS Letter Ruling 202624005