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with respondent (including extensions of time granted by
respondent), much information and many documents necessary for
Exxon to file with respondent complete and accurate income tax
returns were not available to Exxon’s income tax return
preparers.
After filing the original consolidated corporation income
tax returns with respondent, Exxon’s employees responsible for
the accuracy and filing of Exxon’s income tax returns continued
to gather information relating to Exxon’s many businesses in the
United States and throughout the world with respect to various
income, expense, and credit items.
For each of the years 1972 through 1978, respondent's
representatives audited Exxon’s consolidated corporation income
tax returns. During the audits, Exxon's and respondent's
representatives maintained a relatively open and congenial
relationship with each other. Respondent's audits commenced with
a meeting between representatives of Exxon and respondent during
which guidelines and ground rules for the conduct of the audits
were discussed and agreed upon. Procedures were agreed upon for
the exchange of information and for the handling of proposed
adjustments.
During the audits, the general intent of Exxon’s and of
respondent’s representatives was to resolve by agreement and
without protest, appeal, or litigation as many adjustments as
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