Exxon Corporation - Page 2




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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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