PDV America, Inc. and Subsidiaries - Page 3

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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                   
                                  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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