- 2 - petitioners' Federal income taxes for the years 1972 through 1978.1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. FINDINGS OF FACT 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. Hereinafter, petitioners will be referred to simply as Exxon. The businesses in which Exxon was engaged primarily involved exploration, production, transportation, and sale of crude oil and natural gas and manufacture of petroleum products. Additional businesses in which Exxon was engaged involved exploration and mining of coal and uranium, production of nuclear fuel, and businesses unrelated to the energy field such as manufacture and sale of office supply equipment. Exxon constituted one of the largest groups of industrial corporations in the United States. Exxon filed consolidated U.S. corporation income tax returns. The preparation of Exxon’s consolidated corporation 1 Other issues were tried and briefed separately and will be the subject of separate opinions.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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