Robert M. Temple - Page 35


                                       - 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

Last modified: May 25, 2011