Union Texas International Corporation, f.k.a. Union Texas Petroleum Corporation - Page 6

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          Energy (EIN 76-0351014), a Delaware corporation.  Effective                  
          December 31, 1991, pursuant to Delaware Corporation Law, New                 
          Petroleum merged into Energy and ceased to exist.  Energy was the            
          surviving corporation under Delaware law and is the petitioner in            
          the instant case with respect to 1985.5                                      
          Issue 1. Equitable Estoppel for the Taxable Periods of 1985                  

               1985 Forms 872--Consent To Extend the Time To Assess Tax                
               In the 1984 reorganization, Old Petroleum transferred its               
          domestic oil and gas properties to New Petroleum, then known as              
          Properties.  Thus, the responsibility for filing WPT returns                 
          shifted from Old Petroleum to Properties.  On March 5, 1985,                 
          Properties changed its name to New Petroleum.  Despite the name              
          change, New Petroleum continued to file its Forms 720, Quarterly             
          Federal Excise Tax Returns (Forms 720), for the first three                  
          taxable quarters of 1985 under the name of Properties.                       
               To keep the period of limitations open while respondent                 
          continued to conduct the WPT examination of New Petroleum for the            
          1985 taxable periods, respondent and New Petroleum began                     
          executing a series of Forms 872, the last of which was meant to              
          extend the limitations period to June 30, 1994.  At that time,               
          what respondent's WPT revenue agents (WPT agents or agents) did              


          5    When this opinion addresses the actions of the actual                   
          parties to this litigation, the term "petitioners" refers to                 
          Energy and International.                                                    
               When references in this opinion apply to all of the                     
          affiliated Union Texas Petroleum corporate entities, either the              
          term Union Texas companies or affiliated corporations is used.               


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