- 14 - After discussions and negotiations with regard to the information, Exxon's and respondent's representatives agreed that costs relating to repair of Exxon's oil refineries that on Exxon's consolidated corporation income tax returns had been expensed were to be capitalized as follows: Year Capitalized Refinery Repair Costs 1972 $ 9,807,560 1973 8,084,376 1974 11,963,680 1975 4,515,610 1976 2,504,448 In general, adjustments made by respondent that Exxon formally protested beyond the audit level to respondent's Appellate Division and/or in litigation represented issues of importance to Exxon and to the oil and gas industry. Examples of such protested adjustments are the treatment of construction costs of offshore drilling platforms as intangible drilling and development costs and the eligibility of pipeline right-of-way costs for depreciation and investment tax credits. For 1972 through 1978, respondent's audits concluded with issuance to Exxon of Revenue Agent’s Reports (RAR’s). Each RAR summarized respondent's proposed adjustments and set forth proposed income tax deficiencies for each year. By the end of respondent’s audits of Exxon for 1972 through 1978, respondent had made hundreds of adjustments to Exxon’sPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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