The Surgeon's Ledger
How IRC Section 263(c) converts drilling costs into active-income deductions, and the at-risk and AMT limits that define them.
What you’ll learn
- Why surgeons' active income is so hard to shelter
- How Sections 263(c) and 469(c)(3) work together
- The limits: at-risk rules and the AMT preference
- Seven questions to bring to your CPA
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Contents
- Executive Summary Why active professional income needs a different kind of offset
- Why the Issue Matters The limits of 401(k) and IRA planning at this income level
- Foundational Concepts Intangible vs. tangible drilling costs and the Section 263(c) election
- The IDC Deduction in Detail Project-specific IDC ranges, Section 469(c)(3) and entity form
- Limitations and Boundaries At-risk rules, the AMT preference and percentage depletion
- Market Context Why domestic drilling remains active
- Four Structural Questions Entity structure, AFE breakdown, at-risk and AMT, ongoing participation
- Questions for Professional Advisors Seven questions to bring to your CPA or tax attorney
- Summary and Next Steps The statutory pathway and where to go from here
Written for
- Surgeons and physicians Earning active income through W-2, 1099 or K-1 compensation
- Dentists and practice owners Distributing practice profit to themselves as owners
- Attorneys and law firm partners Receiving K-1 income from a professional partnership
- CPAs and tax advisers Reviewing the structure alongside a client


