- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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