- 8 - partnerships’ gross incomes, and the oil producer’s gross sales price, determined without regard to the 2d-tier partnerships’ gross incomes. During 1985, Theodore was a partner in nine single-tier partnerships. During 1985, Theodore was a partner in one multiple tier partnership, Mission Resources Development Drilling Program - Belridge II (hereinafter sometimes referred to as Mission Resources). Mission Resources was a partner in at least one other partnership. Mission Resources’ 1985 information return shows ordinary income of $286,137 from another partnership, identified by name but not otherwise. The record does not include information as to the amount of the gross income stated on this 2d-tier partnership’s 1985 information return. The Ockels do not claim a foreign tax credit on their 1985 tax return, and so do not have any equivalent of the Harlans’ above-noted schedule. The parties have stipulated that the gross income for purposes of section 6501(e) that is “reflected on the Ockels’ 1985 Form 1040 and on the first-tier partnership return [sic] of the partnerships in which the Ockels owned a direct interest”, i.e., excluding “the flow of gross income from” the 2d-tier partnerships, is $407,819. This total includes Theodore’s share of the gross receipts of the independent oil producer.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011