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.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011