Exxon Corporation and Affiliated Companies - Page 16




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               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 the              






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