- 5 -
possible. No agreement, however, was entered into or reached
between Exxon’s and respondent’s representatives as to
specifically when and how Exxon’s representatives would
communicate to respondent’s representatives Exxon’s agreement
with and decision not to protest discrete audit adjustments.
During respondent’s audits, respondent's representatives
examined Exxon’s books and records and, generally through
information document requests (IDR's), requested information and
documents from Exxon.
As adjustments were identified with regard to Exxon’s
Federal income tax liabilities, respondent's representatives
would prepare and provide to Exxon’s representatives written
Notices of Proposed Adjustment (Forms 5701) describing the
amounts and nature of the adjustments.
Also during the audits, Exxon’s representatives would
provide to respondent’s representatives information regarding
income, expense, and credit items that Exxon's representatives
had identified as not being reflected accurately on Exxon’s
consolidated corporation income tax returns. Items so provided
by Exxon’s representatives to respondent's representatives are
referred to by Exxon and herein as “volunteered” adjustments.
Some of the volunteered adjustments represented adjustments in
favor of Exxon and some in favor of respondent.
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Last modified: May 25, 2011