114 T.C. No. 15 UNITED STATES TAX COURT CHARLES E. AND SHERRIE R. STRANGE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8602-98. Filed March 29, 2000. Ps paid State nonresident income tax to nine States on net royalty income derived from their interests in oil and gas wells located within those States. Ps reported all their royalty income on Schedules E, Supplemental Income and Loss, which they attached to their Federal income tax returns. In calculating their total net royalty income, petitioners deducted the State income taxes they paid. Consequently, petitioners deducted the State nonresident income taxes in computing their adjusted gross income for the years at issue. Held, the addition of sec. 164(a)(3), I.R.C., by the Revenue Act of 1964, Pub. L. 88-272, sec. 207(a), 78 Stat. 19, 40, did not change the existing law with respect to the deduction of State income taxes. Held, further, State nonresident income taxes are not "attributable" to property held for the production of royalties and, therefore, are not deductible underPage: 1 2 3 4 5 6 7 8 9 Next
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