Exxon Mobil Corporation and Affiliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 1















                                   114 T.C. No. 20                                    



                               UNITED STATES TAX COURT                                


                  EXXON MOBIL CORPORATION AND AFFILIATED COMPANIES,                   
                 f.k.a. EXXON CORPORATION AND AFFILIATED COMPANIES,                   
             Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent              


               Docket Nos. 18618-89, 18432-90.    Filed May 3, 2000.                  


                    Held:  For the years before the Court,                            
               $204 million (reflecting petitioners’ 22-percent share                 
               of a total $928 million) in estimated dismantlement,                   
               removal, and restoration (DRR) costs relating to                       
               fieldwide oil production equipment and facilities                      
               located in the Prudhoe Bay oil field on the North Slope                
               of Alaska is not sufficiently fixed and definite to be                 
               accruable under the all-events test of sec. 1.461-                     
               1(a)(2), Income Tax Regs.                                              
                    Held, further, for the years before the Court,                    
               $24 million (reflecting petitioners’ 22-percent share                  
               of a total $111 million) in estimated DRR costs                        
               relating specifically to oil wells and to well drilling                
               sites located in the Prudhoe Bay oil field:  (1) Is                    
               sufficiently fixed, definite, and reasonably                           
               determinable to satisfy the all-events accrual test of                 
               the accrual method of accounting; (2) is not accruable                 
               as a capital cost because such accrual would constitute                





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