- 39 - future". The notes to the financial statements explained that, as a result of the acquisition of Tri-Power, petitioner gained access to "substantial tax loss carryforwards which are available to reduce future income taxes." The 1986 annual report also reiterated petitioner's continued commitment to its acquisition program. III. Petitioner's Operations After the Acquisition A. Transfer of Petitioner's Oil and Gas Properties to Tri-Power On December 1, 1986, Tri-Power's name was changed to Plains Petroleum Operating Co. (to avoid confusion, however, we will continue to refer to Plains Petroleum Operating Co. as Tri- Power). Also on December 1, 1986, petitioner transferred all of its oil and gas properties to Tri-Power (the December 1, 1986, property transfer will sometimes be referred to as the dropdown and the properties transferred will be referred to as the dropdown properties).27 Petitioner intended to maintain Tri- Power as a wholly owned subsidiary, and the dropdown was an integral part of petitioner's plan to acquire Tri-Power. For each of the years 1987 through 1996, the Tri-Power properties produced oil and gas amounting to approximately 5 percent of the production from the dropdown properties during 27 Petitioner used only one operating subsidiary, Tri-Power, until 1992, when it organized Plains Petroleum Gathering Co.Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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