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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.
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