Exxon Mobil Corporation and Affiliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 30




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            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            located in the lower 48 States, Exxon has withdrawn its claims            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.                                                               




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