- 3 - 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 respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011