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ENGLE v. COMMISSIONER

Docket No. 6219-79.

76 T.C. 915 (1981)

FRED L. AND MARY A. ENGLE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 8, 1981.

Attorney(s) appearing for the Case

Thomas J. Donnelly, for the petitioners.

Robert M. Fowler, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $4,957.65 in petitioners' Federal income tax for 1975. Petitioners failed to take exception to certain items of adjustment; therefore, the only issue for decision is whether a percentage depletion deduction is allowable under section 613A1 with respect to $7,600 that petitioners received in 1975, as advance royalties, under the terms of their...

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