- 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 NextLast modified: May 25, 2011