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Table 6
Royalty Income
Year Reported Respondent Actual Omitted
1982 $14,318 $24,647 $14,318 1-0-
1983 33,599 264,469 64,469 $30,870
1984 37,979 67,575 367,575 29,596
1985 21,641 23,954 21,641 -0-
1986 12,500 25,730 25,730 13,230
1 As to 1982, see infra note 11 and text following note 9 reference.
2 Respondent determined petitioner's royalty income for 1983 by taking the
1984 royalty income amount that respondent had determined, and adjusting that
figure downward according to the change in the Consumer Price Index.
3 One of the 1984 royalty items was from Phillips Petroleum Co., in the
amount of $32,213, from which $6,408 was withheld. Petitioner did not claim
credit for this withholding on his 1984 income tax return.
Deductions
On his 1982 tax return, petitioner claimed Schedule C
depreciation deductions as shown in table 7.
Table 7
Asset Depreciation Claimed
1981 Chevrolet pickup truck $1,774
House trailer 1,776
1979 Cessna 180 1,900
Tractor and implements 800
Total 6,250
Petitioner used the 1981 Chevrolet pickup truck to some
extent in his law practice and Hall Farms. He also used the
pickup truck to drive to and from work, and to look at drilling
rigs. In 1982 petitioner paid $1,087 interest to GMAC on a loan
to finance his buying of this pickup truck. Petitioner, rather
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