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Background
The parties have stipulated the facts applicable to
the issue considered in this opinion. During the period
1971 through 1993, petitioner was the common parent of an
affiliated group of corporations that included Cordero
Mining Co. or one of its predecessors, Sunedco Coal Co.
and Sunoco Energy Development Co. When we use the term
“Cordero” in this opinion, we mean Cordero Mining Co.
and its predecessors. For each of the years in issue,
Cordero was a member of petitioner’s affiliated group of
corporations and was included in the consolidated return
filed by petitioner on behalf of the group. At the time
the instant petition was filed on its behalf, petitioner’s
principal place of business was in Philadelphia,
Pennsylvania.
Before 1971, Cordero engaged in coal mining in the
Powder River Basin in Wyoming. In 1971, Cordero acquired a
working interest in a Federal lease of 6,560 acres of land
near Gillette, Wyoming, that contained approximately 500
million tons of coal reserves. We sometimes refer to this
property as the Gillette mine or the Gillette property.
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