Exxon Mobil Corporation and Affiliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 47




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          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-site                  





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