Problems on Parties Eligible to make an IDC Election

Note (LL=Landowner Larry, WB=Wildcat Bill DD=Driller Dan)

1. LL and WB enter into an oil & gas lease with Larry retaining 1/8^th royalty and Bill receiving the entire working interest. Is either LL or WB eligible to make an election to expense IDC?
2. Assume the same facts as problem 1, but Bill, as sub-lessor, assigns the entire working interest in the lease to FF, retaining a 1/16^th -overriding royalty interest who is eligible to make an election to expense IDC?
3. Does it make a difference in eligibility to expense IDC if Bill retains a net profit interest (entitling him to of the net profits from the property) instead of the overriding royalty interest?
4. Bill assigns the entire working interest acquired in prob 1 above to FF, subject to a 100k production payment (payable out of 25% of production), instead of an overriding royalty. (Ignore any interest issues that could arise.) Who can make an election to expense IDC on the property? See IRC Sec 636(b).
5. LL enters into an oil & gas lease w WB and DD, each securing a 50% working interest in the lease, with L retaining a 1/8^th. Royalty interest. Are Bill & or Dan eligible to make an election to expense IDC? What about LL? Assume for this problem that the parties make an effective election under IRC 761 (a) to be excluded from partnership treatment under subchapter K of the code.
6. Assume the same facts in Prob 5 above, but the parties do not elect to be excluded from tax partnership treatment under sub-chapter K of the code and thus form a tax partnership. Does this make a difference as to eligibility to make an election to expense IDC?
7. Corp XYZ jointly owned 50/50 by FF & WB enters into an oil & gas lease w LL receiving the entire working interest. Which party or parties can make an election to expense IDC?
8. Corp X, an integrated oil co, as defined under IRC sec 291(b)(4), enters into an oil & gas with LL securing 100% of the working interest & LL retaining a 1/8^th royalty. Can corp. X make an election to exp IDC?
9. WB secures an oil & gas lease from LL securing 100% of the working interest, with LL retaining a 1/8^th royalty. Bill contracts with the DD to drill a well for a cash payment of $10/ft. Can DD make an election to exp IDC? Can WB make an election to exp IDC even though Bill contracts for the drilling?
10. Assume the same facts as prob 9, except that B enters into a turnkey contract w DD to deliver a completed well for $100k/ Can WB make an election to deduct IDC and if so, what amount would qualify? See Rev Rule 73-211, 1973-1 C.B. 303
11. LL enters into an oil & gas lease with WB, retaining 18^th royalty & granting 100%.% of the working interest to WB. WB assigns 25% of the working interest to DD in exchange for DD drilling a well. DD holds the entire working interest until drilling expense is offset. Who is eligible to make an election to exp IDC?
12. Does it make a diff in prob 11 if DD only holds of the working interest but funds 100% of the drilling exp? How is the 75% excess drilling cost treated?
13. LL enters into an oil & gas lease with WB, retaining 18^th royalty & granting 100% of the working interest to WB. WB holds other leases & mase an election to exp IDC in the pan B capitalize IDC associated with drilling on the lease with Larry Landowner (LL)?