- 16 - For 1972 through 1978, after paying the agreed tax deficiencies determined by respondent on audit and the interest due thereon, Exxon filed with respondent a number of claims for refund relating to unrelated items of income, expense, and credit, which claims for refund for a number of the years exceed the amounts paid by Exxon as tax deficiencies relating to the agreed adjustments for each year. As indicated, however, petitioners did not contest, through protests or refund claims, the adjustments relating to the four major agreed adjustments or the adjustments relating to the other agreed adjustments. For financial accounting purposes, Exxon accrued ratably for each year interest on estimated net tax deficiencies. Accrual of Deficiency Interest on Exxon’s Income Tax Returns Exxon’s consolidated corporation income tax returns for 1972 through 1978 were prepared on the accrual method of accounting, and Exxon used the accrual method of accounting to accrue interest expense. On its consolidated corporation income tax returns as filed for 1972 through 1978, Exxon did not accrue ratably interest on the income tax deficiencies that respondent determined for each year until the underlying and related tax deficiencies were set forth in agreed Forms 870, in closing agreements, or until thePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011