- 30 - to Exxon’s oil wells located in the lower 48 States (as well as those relating to the Prudhoe Bay oil field), respondent continues to disallow the accrual of estimated DRR costs. With regard to the accrual of DRR costs relating to foreign offshore oil drilling platforms and to Exxon’s oil wells located in the lower 48 States, Exxon has withdrawn its claims for refund with regard thereto. In the referred-to claims for refund, the PBU and Exxon have raised the issue of whether they may accrue estimated DRR expenses relating to Prudhoe Bay beginning in 1977, the first year of the PBU partnership’s existence, and Exxon has pending refund claims on the issue beginning with each year of the PBU partnership. As explained, Exxon’s primary position in these cases is that estimated DRR costs relating to the oil-producing equipment and facilities located in the Prudhoe Bay field should be accruable, in the year such equipment and facilities are constructed and installed, as capital costs of the facilities and depreciated under the relevant tax depreciation system (for the years in issue--ADR and ACRS). Further, with regard to estimated DRR costs that are capitalized and that relate specifically to oil wells and to cleanup of oil well sites, Exxon claims that investment tax credits under section 38 and intangible drilling costs under section 263(c) should be allowed.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011