Roger Muldavin, et al. - Page 4

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          petitioners' fractional interest in the oil produced and saved              
          from the property was 79.39/80.00 of one-eighth royalty interest            
          (or 0.1240468 in decimal).                                                  
               During the years at issue, petitioners received and reported           
          on their tax returns gross royalty income from the well                     
          identified as Muldavin 2-13 in the following amounts:                       
                         Year           Amount                                        
                         1985           $598,561                                      
                         1986           419,957                                       
                         1987           287,085                                       
                         1988           169,347                                       
                         1989           157,944                                       
          In respondent's determinations, the foregoing amounts were                  
          reduced to take into account windfall profit taxes, depletion               
          allowance at 15 percent, legal fees, and State severance taxes.             
               In order to enable us better to focus on the question of the           
          proper depletion allowance, we first address the following other            
          issues raised by petitioners:                                               
               (1)  They contend that our jurisdiction is defective because           
          respondent lacked authority to issue the deficiency notices                 
          involved herein.  Those assertions are similar to those raised by           
          tax protesters which have been uniformly rejected by cases too              
          numerous to cite.  They are totally without merit.                          

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