- 2 - Thomas P. Marinis, Jr., Sarah A. Duckers, and Charles T. Fenn, for petitioner. Emron M. Pratt, Jr. and Todd A. Ludeke, for respondent. OPINION LARO, Judge: The parties submitted this case to the Court without trial. See Rule 122. Petitioner petitioned the Court to redetermine respondent's determination of income tax deficiencies of $399,369 and $753,089 for its taxable years ended September 30, 1991, and September 30, 1992, respectively. We must decide the cost recovery period of certain natural gas recovery systems under the modified accelerated cost recovery system (MACRS). Petitioner argues for a 7-year recovery period. Respondent argues for a 15-year recovery period. We hold for respondent. Unless otherwise noted, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. References to "asset class" are to the asset classes set forth in Rev. Proc. 87-56, 1987-2 C.B. 674. Background All facts are stipulated. The stipulated facts and exhibits submitted therewith are incorporated herein by this reference. Petitioner is the common parent of an affiliated group of corporations which file consolidated Federal income tax returns.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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