Exxon Mobil Corporation and Affiliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 40




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               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 to           




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