RIFE v. COMMISSIONER

Docket No. 89682.

41 T.C. 732 (1964)

M. O. RIFE, JR., AND MAIDEE W. RIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 6, 1964.


Attorney(s) appearing for the Case

Whitfield J. Collins and Robert A. Watson, for the petitioners.

Douglas M. Moore, for the respondent.


SCOTT, Judge:

Respondent determined deficiencies in the income tax of petitioners for the calendar years 1954, 1955, and 1956 in the amounts of $91050.61, $70,522.83, and $1,384.13, respectively.

The issues for decision are:

(1) Whether petitioners who report their income on a cash basis are entitled to deduct intangible drilling and development expenses in the year that a partnership of which one of...

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