- 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 Next
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