- 50 - 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 andPage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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