- 33 -                                         
          $3,471,045, $3,060,042, and $2,109,854.15  On August 22, 1994,               
          each petitioner timely filed a petition with this Court                      
          contesting the entire amount of the deficiencies asserted. In                
          addition thereto, petitioners claimed overpayments of WPT of                 
          $6,107,901, $5,969,611, and $7,931,434 for the taxable periods of            
          1983, 1984, and 1985, respectively, resulting from a                         
          recomputation of their WPT NIL calculations.  At trial and on                
          brief, respondent contends that Petroleum's WPT NIL                          
          recomputations are not in accord with section 1.613-5(a), Income             
          Tax Regs., because they impermissibly deviated from the                      
          percentage depletion calculations claimed on Petroleum's original            
          returns.16  Accordingly, respondent argues that petitioners                  
          15   The deficiencies as determined by respondent are in windfall            
          profit taxes for the taxable periods in issue and in the amounts             
          set forth below:                                                             
          Taxable Period Ended                Amount                                   
          Mar.  31, 1983                $898,508                                       
          June  30, 1983                      882,297                                  
          Sept. 30, 1983                865,264                                        
          Dec.  31, 1983                824,976                                        
          Mar.  31, 1984                      874,332                                  
          June  30, 1984                      594,829                                  
          Sept. 30, 1984                649,637                                        
          Dec.  31, 1984                941,244                                        
          Mar.  31, 1985                      554,711                                  
          June  30, 1985                      516,123                                  
          Sept. 30, 1985                535,574                                        
          Dec.  31, 1985                503,446                                        
               Total                    8,640,941                                      
          16   Respondent further argued that petitioners' new WPT NIL                 
          calculations should be rejected, because they are not defensible             
          under cost accounting principles.  We find it unnecessary to                 
                                                              (continued...)           
Page:  Previous   20   21   22   23   24   25   26   27   28   29   30   31   32   33   34   35   36   37   38   39   NextLast modified: May 25, 2011