Salty Brine 1, Limited v. United States

W. EUGENE DAVIS, Circuit Judge:

Plaintiff Thomas & Kidd Oil Production, Ltd. (“TKOP”) appeals from the district court’s determination, after a nine-day bench trial, that the transfer of certain overriding royalty interests through a complicated transaction was an invalid attempt to assign income. The record amply supports this finding and supports the district court’s conclusion that the income was taxable to TKOP for the 2006 tax year. We affirm.

I. Introduction

On April 5, 2010, The Commissioner of Internal Revenue issued a Notice of Final Partnership Administrative Adjustment to TKOP for the…