Sunoco, Inc. and Subsidiaries - Page 12

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             percent of the amount allowable as a deduction under                     
             section 616(a), as required by section 291(b)(1), and it                 
             amortized that amount over 60 months beginning with the                  
             month in which the costs were paid or incurred, as                       
             permitted by section 291(b)(2) as in effect during 1987                  
             through 1990.  For alternative minimum tax purposes,                     
             Cordero also treated overburden removal costs as mine                    
             development costs, and Cordero took advantage of the                     
             adjustments permitted under section 56(a)(2) under which a               
             taxpayer’s taxable income for the taxable year is adjusted               
             for purposes of computing alternative minimum taxable                    
             income by capitalizing the amount allowable as a deduction               
             under section 616(a) (determined without regard to section               
             291(b)) and amortizing that amount ratably over the 10-year              
             period beginning with the taxable year in which the                      
             expenditures were made.                                                  
                  For each of the taxable years 1991 through 1993,                    
             Cordero elected under section 59(e) to amortize all of its               
             mine development costs.  In accordance with this election,               
             Cordero capitalized all of its mine development expenses                 
             and amortized those costs over 10 years.  Cordero’s                      
             election under section 59(e) covered overburden removal                  
             costs of $17,129,007 that were paid or incurred in 1991,                 
             overburden removal costs of $19,799,530 that were paid                   






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