- 35 - 1990 Royalty Income Payor Amount Concessions Total Scavenger Oil Corp. 1$1,800 $0 $1,800 Pennzoil Products 257 0 257 Pennzoil Products 289 0 289 Pennzoil Products 443 0 443 Total 2,789 0 2,789 Total Income2 78,949 (1,800) 77,149 1Respondent originally included payment from Scavenger Oil in its computation of petitioner’s gross receipts from the sale of animals and for royalty income. In respondent’s concessions, the double counting of this one check was eliminated. We note that the record is not clear on whether the payment was for the purchase of an animal or for royalty payments. Nevertheless, it is clear that petitioner received an $1,800 payment from Scavenger Oil in 1990. Whether the check represents payment for the purchase of an animal or royalty income has no bearing on the outcome of this case. In either case, it is taxable income to petitioner as ordinary income. 2Includes totals from previous page.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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