Union Texas International Corporation, f.k.a. Union Texas Petroleum Corporation - Page 1

                                   110 T.C. No. 25                                     


                               UNITED STATES TAX COURT                                 


                   UNION TEXAS INTERNATIONAL CORPORATION, f.k.a.                       
                  UNION TEXAS PETROLEUM CORPORATION, Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

                      UNION TEXAS PETROLEUM ENERGY CORPORATION                         
              SUCCESSOR BY MERGER TO UNION TEXAS PETROLEUM CORPORATION,                
                f.k.a. UNION TEXAS PROPERTIES CORPORATION, Petitioner                  
                   v. COMMISSIONER OF INTERNAL REVENUE, Respondent                     


               Docket Nos. 15182-94, 15183-94.          Filed May 21, 1998.            

                         R and P's predecessor, NP, executed a                         
                    series of three Forms 872 for 1985.  R did                         
                    not know at the time of signing the Forms 872                      
                    that NP had merged with P and that NP no                           
                    longer had authority to extend the period of                       
                    limitations after Dec. 31, 1991.                                   
                         Effective Dec. 31, 1982, P's                                  
                    predecessor, OP, entered into an agency                            
                    agreement with PR, a sister company, to                            
                    process and sell propane for OP and NP to                          
                    unrelated third parties.  OP and NP retained                       
                    title to its propane until PR sold it to                           
                    unrelated third parties.  PR also sold its                         
                    own propane to T, a related retailer.                              



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