- 2 - Ps assert that they should be permitted to use differing allocations for computing the Windfall Profit Tax (WPT) and Percentage Depletion Net Income Limitation (NIL). 1. Held: P, Energy, is estopped to deny the validity of the Forms 872. Knowledge of the merger is not attributed to R's WPT agents; computerized information of the merger was not accessible to them. 2. Held: Ps are independent producers, because they did not sell their propane to T. 3. Held: Sec. 4988(b)(3)(A), I.R.C., requires Ps to compute the NIL in the same manner under sec. 4988(b)(3)(A), I.R.C. and sec. 613, I.R.C. Jasper George Taylor III, Charles Washington Hall, William H. Caudill, and John B. Kinchen, for petitioners. Sheri Wilcox, for respondent. OPINION PARR, Judge: In these consolidated cases, respondent determined the following deficiencies in windfall profit tax (WPT) for the taxable periods of 1983, 1984, and 1985, respectively: $3,471,045, $3,060,042, and $2,109,854. Respondent determined the deficiencies against Union Texas Petroleum International (International) for 1983 and 1984, and against Union Texas Petroleum Energy (Energy) for 1985. In their petitions, petitioners raised an issue pursuant to sectionPage: Previous 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