Roy E. and Linda Day - Page 3

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                  All section references, unless otherwise specified, are to                             
            sections of the Internal Revenue Code in effect for the years at                             
            issue.  Statutory provisions applicable to the years in issue are                            
            reproduced in the Appendix.                                                                  
                  All of the facts have been stipulated.  The Court finds                                
            these facts.  This reference incorporates the stipulation of                                 
            facts and attached exhibits.  Petitioners were married and                                   
            resided in Morgantown, West Virginia, when they filed their                                  
            petition.                                                                                    
                  Respondent determined deficiencies in petitioners' Federal                             
            income tax for 1988, 1989, and 1990, in the amounts of $6,791,                               
            $14,825, and $10,127, respectively.                                                          
                  Petitioners invested in oil- and gas-producing properties,                             
            the production from which qualified for section 29                                           
            nonconventional fuel source credits of $12,706 in 1988, $14,210                              
            in 1989, and $14,729 in 1990.  Petitioners had depletion,                                    
            intangible drilling costs, accelerated depreciation, and                                     
            adjustments in 1988, 1989, and 1990 totaling $37,910, $76,329,                               
            and $70,502, respectively.  These amounts were added to                                      
            petitioners' taxable income to calculate their AMTI.                                         
                  Petitioners' 1988 taxable income as determined by respondent                           
            was $115,374, and their RIT as so determined was $30,611.                                    
            Respondent also determined self-employment tax to be $5,859 for                              
            the taxable year 1988.  The Days had no AMT liability for 1988.                              
            For 1989, petitioners' taxable income as determined by respondent                            




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