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HEITZMAN v. COMMISSIONER

Docket No. 33436-84.

53 T.C.M. 241 (1987)

T.C. Memo. 1987-109

Charles J. Heitzman and Sharon Lee Heitzman v. Commissioner.

United States Tax Court.

Filed February 24, 1987.

Attorney(s) appearing for the Case

Martin N. Gelfand, for the petitioners. Howard Rosenblatt, for the respondent.

Memorandum Opinion

SHIELDS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1979 of $55,263. The case is before us at this time on a motion by each party for partial summary judgment under Rule 121.1 The issues raised in each motion are whether petitioners are entitled to a deduction attributable in part to a minimum annual royalty and in part to intangible drilling costs accrued in 1979 by a...

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