- 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...)
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