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The term "immediate vicinity of the well" would have a meaning for IRC § 907 that is substantially identical to the meaning for depletion.
Because income from the production and sale of oil and gas product is equal to the sum of FOGEI and FORI, once the total income and FORI are established, FOGEI can then be determined by subtracting FORI from total income.Examples of FOGEI assets include: Most of the disagreements regarding classification of assets between FOGEI and FORI involve transportation and processing assets. Not defined in IRC § 907 or the regulations under that section.Attachment 1 provides a more detailed discussion of the classification of those assets as FOGEI or FORI based on definitions provided in the regulations and on common usage of terms within the oil and gas industry. §1.907(c)-1(b)(1) as: [T]axable income (or loss) derived from sources outside the United States and its possessions from the extraction (by the taxpayer or any other person) of minerals from oil or gas wells located outside the United States and its possessions or from the sale or exchange of assets used by the taxpayer in the trade or business of extracting those minerals. However, the term has been used for many decades for determining gross depletable income for purposes of depletion: Treas. §1.613-3 Gross income from the property--Oil and gas wells.In order to improve consistency and reduce the administrative burden on both taxpayers and the IRS, this LMSB Directive provides guidance to international examiners (IEs) and specialists on the application of the most two commonly used methods for determining FOGEI (and FORI) when there is no ascertainable market price for the oil and gas in the immediate vicinity of the well.Discussion Methods for Determining FMV in the Immediate Vicinity of the Well Most taxpayers use either a residual (rate of return) method or a proportionate profits method to determine FOGEI.
FOGEI is defined in the Code and regulations as taxable income derived from the extraction of minerals from oil or gas wells based on the fair market value (FMV) of the minerals in the immediate vicinity of the well.