- 47 - Accrual of Estimated Prudhoe Bay Well-Site DRR Costs as Capital Costs or as Current Business Expenses Although we are satisfied that Exxon’s attempted accrual of $24 million in estimated DRR costs relating to Prudhoe Bay well plugging and well-site cleanup would satisfy the all-events test of the accrual method of accounting, respondent argues that Exxon may not, without respondent’s permission, accrue such $24 million into the tax bases of its share of Prudhoe Bay capital asset costs and claim thereon accelerated depreciation, investment tax credits (ITC), and intangible drilling costs (IDC). We agree with respondent. We believe that Exxon’s claim to such capitalization, accelerated depreciation, ITC, and IDC constitutes a substantial deviation from the current ordinary business expense treatment of Prudhoe Bay well-site DRR costs (at the time of performance of related DRR work) that Exxon has been using on its Federal corporation income tax returns as filed and that such a change would constitute a “change” in Exxon’s method of accounting for DRR costs for which respondent’s permission is required. See sec. 446(e), particularly the last sentence of sec. 1.446- 1(e)(2)(ii)(b), and (3)(i), Income Tax Regs. Not having obtained such permission and absent a finding herein that respondent abused his discretion in not granting such permission, Exxon is not allowed to accrue estimated Prudhoe Bay well-site DRR costs into the capital cost bases of the wells and the well-sitePage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
Last modified: May 25, 2011