Exxon Mobil Corporation and Affiliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 50




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               Respondent argues that Exxon’s alternative accrual as                  
          ordinary business expenses in the year wells are drilled of the             
          $24 million in estimated Prudhoe Bay well-site cleanup costs                
          (that we determine satisfy the all-events test of the accrual               
          method of accounting) would distort Exxon’s income.  Exxon                  
          responds that under its alternative claim to currently expense              
          estimated Prudhoe Bay DRR costs its income would not be distorted           
          for Federal income tax purposes.                                            
               Section 446(b) grants respondent broad discretion to                   
          determine whether a particular method of accounting clearly                 
          reflects income and to impose such method of accounting as in               
          respondent’s opinion does clearly reflect income.  Respondent’s             
          determination is to be respected unless it is found to be an                
          abuse of discretion.  See Thor Power Tool v. Commissioner, 439              
          U.S. 522, 532 (1979); Ford Motor Co. v. Commissioner, 71 F.3d               
          209, 212 (6th Cir. 1995), affg. 102 T.C. 87 (1994); Prabel v.               
          Commissioner, 882 F.2d 820, 823 (3d Cir. 1989), affg. 91 T.C.               
          1101 (1988).                                                                
               Herein, under Exxon’s alternative claim, Exxon would fully             
          write off $24 million in estimated well-site DRR costs                      
          immediately in the years wells in the Prudhoe Bay oil field were            
          drilled.  Such current expense treatment would be unrelated to              
          the years thereafter in which oil production from the wells                 
          occurred and income from sale of the oil was realized and                   






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