Exxon Corporation and Affiliated Companies - Page 6




                                        - 6 -                                         

               Upon receipt of information regarding volunteered                      
          adjustments, respondent’s representatives would not automatically           
          accept the proposed adjustments.  Rather, respondent’s                      
          representatives would review, analyze, and audit the information            
          provided by Exxon’s representatives and would make determinations           
          after discussions and negotiations with Exxon's representatives             
          as to the appropriate adjustments, if any, and respondent’s                 
          representatives would propose the adjustments so determined in              
          Forms 5701 that were given to Exxon’s representatives.2                     


          2     IDR No. 85 (Trial Exhibit 137), bears upon the so-called              
          volunteered adjustments for the years 1974, 1975, and 1976.  It             
          establishes:  (1) Respondent’s representatives' awareness of and            
          expectation that volunteered adjustments would be received from             
          Exxon; and (2) respondent’s and Exxon’s representatives'                    
          understanding that respondent's representatives would not                   
          automatically accept the information with regard to volunteered             
          adjustments provided by Exxon's representatives but rather would            
          review and audit the information.  Set forth below is language              
          from IDR No. 85 describing the information requested of Exxon by            
          respondent’s representatives:                                               
               IDR No. 85, Description of Documents Requested                         
                    (1) After a return is filed, taxpayers frequently discover errors 
                    in the return that was filed which include the following:         
                         (a) Deductions claimed which are not deductible              
                         (b) Deductions not claimed which are deductible              
                         (c) Income reported which is not taxable                     
                         (d) Income not reported which is taxable                     
                         (e) Credits not claimed which should be on the return        
                         (f) Credits claimed which are not proper                     
                    (2) Please submit a list of any such items which have been        
                    discovered subsequent to the filing of the returns for 1974, 1975,
                    and 1976.                                                         
                    (3) Please submit a detailed explanation of the items under (2) so
                    this agent can determine if the items should be corrected by      
                    including them in the RAR as an adjustment.                       




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011