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$6,535 in September 1978, and on which he had claimed
depreciation deductions for the years 1978 through 1985.
Petitioner had no other receipts or gross income from De Boer
Drilling Co. for the years 1985-91. Petitioner received and
reported wages in the following amounts on his Federal income tax
returns from 1985 through 1991:
Tax
Year Wages Employer Dates Worked Hrs./Wk.
1985 $89,555 Mobil Exploration 1/1-5/20 50
Norway, Inc.
1986 7,254 Mobil expense reimbursement
1987 14,228 U.S. Army 7/11-10/30 35
Everts Air Fuel 12/1-12/31 35
1988 21,639 Everts Air Fuel 1/1-12/31 35
1989 20,285 Everts Air Fuel 1/10-6/10 35
Craig Taylor Equip. Co. 11/11-12/31 40
1990 31,894 Craig Taylor Equip. Co. 1/1-12/31 40
1991 36,332 Craig Taylor Equip. Co. 1/1-2/15 40
University of Alaska 2/26-12/31 38
In 1987, petitioner attempted to sell the second drill rig,
and entered negotiations to sell it at a price of approximately
$400,000. However, he did not sell it.6
During the years 1985-91, petitioner listed De Boer
Drilling Co. in the Fairbanks, Alaska yellow pages under the
heading "drilling contractors" at a cost of approximately $150 to
6There is no evidence in the record as to what petitioner
did with the first rig after he bought the second rig, and all
further references herein to “the drill rig” are to the second
drill rig.
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