Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 56

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          corporate income tax returns on behalf of itself and its domestic           
          subsidiaries for the taxable years ended December 31, 1979,                 
          December 31, 1980, December 31, 1981, and December 31, 1982, with           
          the District Director, Chicago, Illinois, reflecting Amoco's                
          timely election to: (1) Apply the provisions of the 1983 foreign            
          tax credit regulations retroactively to the years at issue, and             
          (2) apply the "safe harbor" method of determining allowable                 
          foreign tax credits with respect to Egyptian taxes.                         
               Applying the "safe harbor" method in its amended returns,              
          petitioner treated portions of the Egyptian income taxes reported           
          on its original returns as creditable taxes.  The remainder was             
          deducted in computing taxable income.  The amounts reported on              
          petitioner's amended returns are summarized as follows:                     
               Year      Credit Claimed        Deducted          Total                
               1979      $215,414,631        $ 88,601,262   $304,015,893              
               1980      459,881,927         38,204,353     498,086,280               
               1981      383,993,639         173,879,789    557,873,428               
               1982      308,490,746         145,095,933    453,586,679               
               Egyptian income taxes claimed as foreign tax credits by                
          Amoco in 1979 were not utilized to reduce Amoco's 1979 U.S. tax             
          liability and were carried forward to 1980 and subsequent tax               
          years.                                                                      
               On June 18, 1992, respondent issued a statutory notice of              
          deficiency to petitioner for the 1980, 1981, and 1982 tax years.            
          In the notice of deficiency, respondent determined that Amoco               
          Egypt's Egyptian income taxes had not been paid within the                  





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