- 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’s
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011