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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.
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Last modified: May 25, 2011