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income tax returns constituted a time-consuming and difficult
undertaking for employees, accountants, and other tax
professionals and staff hired by Exxon for that purpose. The
preparation of Exxon’s consolidated corporation income tax
returns was particularly difficult due to the large volume, size,
and variety of the many businesses in which Exxon was engaged,
the quantity of information required for the preparation of the
tax returns relating to the businesses in which Exxon was
engaged, and the significant complexity of U.S. and foreign tax
laws to which Exxon’s businesses were subject.
Exxon’s consolidated corporation income tax returns that
were filed with respondent consisted of documents several feet
thick and thousands of pages. During the year and during the
months immediately after the end of the year up until the date on
which each of Exxon’s consolidated corporation income tax returns
was filed, employees in Exxon's tax department gathered
information from Exxon's numerous subsidiary and affiliated
corporations located in the United States and throughout
the world and prepared and assembled Exxon’s consolidated
corporation income tax returns.
In spite of extensive and good faith efforts by Exxon’s
employees to obtain all of the relevant information for
preparation of Exxon’s consolidated corporation income tax
returns, by the time the income tax returns were due to be filed
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