Ridge L. Harlan and Marjory C. Harlan - Page 8




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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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