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consolidated corporation income tax returns, and Exxon’s and
respondent’s representatives had reached agreement on 78 percent
of the total number of adjustments, of which, as indicated, the
four major agreed adjustments represented approximately
85 percent of the net agreed adjustments. Respondent’s audit of
Exxon for 1972 and 1973 ended in 1981. Respondent's audit of
Exxon for 1974, 1975, and 1976 ended in 1985. Respondent's audit
of Exxon for 1977 and 1978 ended in 1989.
After or simultaneously with receiving respondent's RAR's
relating to the years 1972 through 1977, Exxon’s representatives
signed Forms 870 with respect to the agreed adjustments and to
the portions of the proposed tax deficiencies that were agreed.
Respondent then assessed the taxes agreed to and statutory
interest due thereon, and Exxon soon thereafter paid the amount
of the assessed tax deficiencies and interest (the amount of the
interest accrued from the due date of Exxon's consolidated
corporation income tax returns to the date of payment). Also for
1972 through 1977, with regard to certain unagreed issues and tax
deficiencies determined by respondent relating thereto,
respondent issued to Exxon notices of deficiency.
For 1978, at the conclusion of respondent's audit, Exxon did
not enter into a Form 870 agreement. For 1978, respondent issued
a notice of deficiency and assessed the tax deficiency and
statutory interest that Exxon paid.
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