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UNITED STATES v. HILL

No. 91-1421.

506 U.S. 546 (1993)

113 S.Ct. 941

122 L.Ed.2d 330

UNITED STATES v. HILL et ux.

Supreme Court of United States.

Decided January 25, 1993.

Attorney(s) appearing for the Case

Kent L. Jones argued the cause for the United States. With him on the briefs were Solicitor General Starr, Acting Assistant Attorney General Bruton, Deputy Solicitor General Wallace, Ann Belanger Durney, and Charles Bricken.

Richard B. Robinson argued the cause for respondents. With him on the brief was Robert A. Wherry, Jr.*

Souter, J., delivered the opinion for a unanimous Court.

Justice Souter, delivered the opinion of the Court.

Under §§ 56 and 57(a)(8) of the Internal Revenue Code of 1954, 26 U. S. C. §§ 56, 57(a)(8) (1976 ed.), a taxpayer must pay a "minimum tax" on the excess of the allowable depletion deduction for an interest in a mineral deposit over the taxpayer's adjusted basis for that interest. The question presented here is whether the term "adjusted basis," as used in § 57(a)(8), includes certain depreciable...

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