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Petitioner was incorporated under the laws of the
Commonwealth of Pennsylvania. At the time the instant
petition was filed on its behalf, petitioner's principal
place of business and mailing address was in Philadelphia,
Pennsylvania. During each of the tax years in issue,
petitioner was the common parent of an affiliated group of
corporations, as defined in section 1504(a), and it filed a
consolidated Federal income tax return on behalf of itself
and the other members of the affiliated group as permitted
by section 1501.
At all times material to this case, petitioner and
the other members of its affiliated group engaged in the
business of acquiring and developing oil, gas, and other
energy properties, of refining or otherwise preparing the
natural resources produced from the properties for sale
to customers, and of marketing and transporting those
products to customers both in the United States and abroad.
During the years in issue, petitioner and its affiliated
corporations earned income from various sources, domestic
and foreign, including income from interest, dividends, the
production of oil and gas and other hydrocarbons, and the
sale of products derived from the production of
hydrocarbons.
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