Roy E. and Linda Day v. Commissioner

108 T.C. No. 2

UNITED STATES TAX COURT ROY E. AND LINDA DAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20732-94. Filed January 9, 1997. R determined deficiencies in Ps' Federal income tax for the years 1988 through 1990. Ps seek to augment the amount of sec. 29, I.R.C., nonconventional fuel source credits they may take against regular income tax by increasing the availability of such credits under the sec. 29(b)(5), I.R.C., limitation. Ps argue that if their taxable income in each year had not been reduced by tax preference items, the resulting tax payable on that…