Exxon Corporation and Affiliated Companies - Page 11




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          disallowed and that Exxon’s representatives agreed constituted              
          nondeductible capital expenditures because they led to                      
          commercially exploitable energy resources that produced income              
          for Exxon over the course of a number of years:                             

                    Year              Capitalized G&G Costs                           
                    1972                $ 2,029,833                                   
                    1973                4,114,117                                     
                    1974                9,289,354                                     
                    1975                8,701,886                                     
                    1976                9,359,770                                     
                    1977                16,631,441                                    
                    1978                21,757,729                                    

          Proratables Adjustment                                                      
               The second of the four major agreed adjustments (referred to           
          by the parties as the “proratables adjustment”) was made only for           
          1972 through 1976 and involves the characterization or allocation           
          of certain of Exxon's administrative expenses between U.S. and              
          foreign sources.  Allocations of Exxon's expenses to foreign                
          sources decreased Exxon's foreign source income and reduced                 
          foreign tax credits that Exxon could claim against its U.S. tax             
          liabilities.                                                                
               Similar to G&G activity, Exxon’s and respondent’s                      
          representatives generally agreed as to the applicable law                   
          relating to the allocation of administrative expenses between               
          U.S. and foreign sources.  Upon receipt during the audits from              
          Exxon's representatives of information relating to Exxon's                  







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Last modified: May 25, 2011