Strange v. Commissioner
United States Tax Court
Ps paid State nonresident income tax to nine States on net royalty income derived from their interests in oil and gas wells located within those States. Ps reported all their royalty income on Schedules E, Supplemental Income and Loss, which they attached to their Federal income tax returns. In calculating their total net royalty income, petitioners deducted the State income taxes they paid.
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Ps paid State nonresident income tax to nine States on net royalty income derived from their interests in oil and gas wells located within those States. Ps reported all their royalty income on Schedules E, Supplemental Income and Loss, which they attached to their Federal income tax returns. In calculating their total net royalty income, petitioners deducted the State income taxes they paid. Consequently, petitioners deducted the State nonresident income taxes in computing their adjusted gross income for the years at issue. HELD, the addition of sec. 164(a)(3), I.R.C., by the Revenue Act of…
1Opinion of the Court
OPINION
PARR, Judge:
Respondent determined deficiencies of $3,955, $5,379, and $3,983 in petitioners’ Federal income taxes for the taxable years 1993, 1994, and 1995, respectively. The sole issue for decision is whether State nonresident income taxes paid on net royalty income are deductible for purposes of determining adjusted gross income. We hold they are not.
Background
This case was submitted fully stipulated under Rule 122.1 The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in Las Vegas, Nevada, at the time they filed their…
2Cases cited2 opinions
- Tanner v. CommissionerUnited States Tax Court · 1965
- Douglas H. Tanner v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1966
3Cited by3 opinions
- Bakersfield Energy Partners, LP v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Charles E. and Sherrie R. Strange v. CommissionerUnited States Tax Court · 2000
- Strange v. CommissionerUnited States Tax Court · 2000