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
CHARLES E. AND SHERRIE R. STRANGE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Strange v. Commissioner
No. 8602-98
United States Tax Court
114 T.C. 206; 2000 U.S. Tax Ct. LEXIS 22; 114 T.C. No. 15; 145 Oil & Gas Rep. 187;
March 29, 2000, Filed
Decision will be entered for respondent.
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
the…
2Cases cited3 opinions
- Tanner v. CommissionerUnited States Tax Court · 1965
- Douglas H. Tanner v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1966
- Strange v. CommissionerUnited States Tax Court · 2000