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SWIFT, Judge: The issue for decision is whether petroleum
revenue tax (PRT) petitioners paid to the United Kingdom for 1983
through 1988 constitutes, for U.S. income tax purposes, a
creditable income or excess profits tax under section 901 or a
creditable tax in lieu thereof under section 903.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in question,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
The parties have stipulated numerous facts and admissibility
of numerous exhibits. The stipulated facts are so found.
During the years in issue, petitioners constituted an
affiliated group of more than 175 U.S. and 500 foreign subsidiary
corporations. Petitioner Exxon Corp. was the common parent of
the affiliated group, with its principal place of business in
Irving, Texas. Hereinafter, petitioners will be referred to
simply as “Exxon”.
The businesses in which Exxon was engaged primarily involved
exploration for and production, refining, and sale of crude oil,
natural gas, and other petroleum products.
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