- 4 - 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. Discussion 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011