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ENERGY RESOURCES LIMITED PARTNERSHIP v. COMMISSIONER

Docket Nos. 20022-87, 15977-88.

64 T.C.M. 80 (1992)

T.C. Memo. 1992-386.

Energy Resources Limited Partnership, Baumgardner Oil Company, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed July 13, 1992.

Attorney(s) appearing for the Case

Theodore W. Hirsh, 10 Light St., Baltimore, Md., for the petitioner. Deborah Y. Clark, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined adjustments in the partnership items of Energy Resources Limited Partnership (ERLP) as follows:

Year                               Depreciation   Amortization     ITC       Recapture

1983 ...........................    $1,035,216     ($594,144)    $563,168   $4,207,863
1984 ...........................     1,032,520        36,763...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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