- 40 - The rules of financial accounting and a company’s financial treatment of such costs, however, whether correct or incorrect thereunder are not controlling for Federal income tax purposes. See Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 540 (1979). We also note that Exxon, for financial reporting purposes, did not on its financial balance sheets (as distinguished from its financial income statements) accrue any fixed liability relating to estimated DRR obligations at Prudhoe Bay. Exxon argues strenuously that respondent’s position, under which no tax accrual would be allowed for estimated future Prudhoe Bay DRR costs, produces a fundamental and gross mismatch of Exxon’s income and expenses relating to Prudhoe Bay oil recovery. Under the matching principle of Federal income tax accounting, however, only those obligations are to be recognized that are properly accruable (i.e., that satisfy the all-events test). To allow estimated costs of obligations that do not satisfy the all-events accrual test (such as the majority of the estimated DRR costs involved herein) to be accrued and to offset current income is not part of the matching principle. Further, Alaska’s general policy under its constitution for management of Alaska lands (to permit development while at the same time insisting that the environment be preserved or, if necessary, restored to the fullest reasonable extent) does not establish any specific oil company DRR obligations with regard toPage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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