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petitioners’ attempted accrual, for 1979 through 1982, of its
$204 million share of $928 million in total estimated
dismantlement, removal, and restoration (DRR) costs relating to
oil wells and to oil production equipment and facilities in the
Prudhoe Bay oil field on the North Slope of Alaska (North Slope)
would satisfy the all-events test of the accrual method of
accounting. If, for the years in issue, the accrual of any of
the estimated DRR costs would satisfy the all-events test of the
accrual method of accounting, further issues are to be addressed
relating to the amount and method of petitioners’ claimed accrual
thereof.2
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
The parties have stipulated numerous facts and the
authenticity and admissibility of numerous exhibits. The
stipulated facts are so found.
1(...continued)
T.C. Memo. 1999-247 (involving the accrual of deficiency
interest).
2 The issues in these consolidated cases have also been
raised by petitioners in timely filed claims for refund for 1977
and 1978, which claims we understand to be still pending.
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