No one need tell you gentlemen that secondary recovery projects and operations are becoming more numerous and important in the oil and gas industry. We all know that unless such projects and operations are undertaken a substantial amount of reserves will be unrecoverable and lost at least as far as our generation is concerned and perhaps to all future generations.

Of course, lawyers especially are cognizant of the fact that the development and changes in the law lag behind the development and changes in business operations and procedures which are necessitated by our dynamic economy. And as so often happens the laws, whether statutory or case law, do not give a great deal of assurance as to the ultimate legal consequences stemming from a particular operation, transaction, or contract. Consequently, lawyers frequently have to draw heavily upon their imagination tempered with judgment and forecast what the courts will probably hold in a particular situation.

What has been said applies in, the field of federal taxation to a greater degree than in other fields of law. The reason is perhaps simple since the field of income taxation is relatively new as fields of law go, and it is an extremely dynamic field which varies in many respects from year to year, all of which may explain why the field of tax law lends itself to more specialization than other fields might.

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