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System (MACRS) Asset Guideline Class 57.0 of Rev. Proc. 87-56,
1987-2 C.B. 674, 686, and treated as 5-year property under
section 168(e)(1),2 or are included in MACRS Asset Guideline
Class 57.1, and treated as 15-year property under section
168(e)(1).
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulation of facts and the supplemental stipulation of facts
into our findings by this reference.
PDV Holding, Inc., and PDV America, Inc., are Delaware
corporations. PDV Holding, Inc., was created in 1997 as the new
common parent of the PDV America, Inc., affiliated group.
Accordingly, we shall refer to PDV Holding, Inc., and PDV
America, Inc., collectively as petitioner.
Petitioner timely filed consolidated Forms 1120, U.S.
Corporation Income Tax Return, for the taxable years 1996 and
1997 on behalf of itself and its affiliated corporations.
Petitioner’s principal office was located in Tulsa, Oklahoma,
when it filed the petitions.
A. CITGO’s Business
Petitioner’s subsidiary, CITGO Petroleum Corp. (CITGO), a
2All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Monetary amounts are
rounded to the nearest dollar.
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