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concessions or signing written stipulations of settlement that
were filed with this Court during pendency of these cases.
Occasionally, Exxon's representatives indicated agreement to
proposed audit adjustments in their written responses to IDR's.
For each year, more than 250 audit adjustments to Exxon’s
consolidated corporation income tax returns were identified and
proposed by respondent’s representatives.
During respondent's audits of Exxon’s consolidated
corporation income tax returns for 1972 through 1978, there were
what Exxon refers to as four major agreed adjustments that were
identified and raised by respondent’s representatives and that,
by the end of each audit, were agreed to by Exxon’s and
respondent’s representatives and that increased Exxon's U.S.
source income for each year (the four major agreed adjustments).
However, in their petitions to this Court with regard to income
tax deficiencies that respondent determined against Exxon for
1979 through 1982, Exxon did object to and did challenge the
correctness of the four major agreed adjustments.
The four major agreed adjustments represent approximately
85 percent of the total adjustments that, by the end of
respondent's audits of Exxon for 1972 through 1978, were agreed
to by Exxon’s and respondent’s representatives and that were not
further protested or litigated by Exxon (the agreed adjustments).
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