Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 4

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               Upon audit, respondent determined substantial deficiencies             
          in petitioners’ Federal income taxes for 1979 through 1985.                 
               During the course of respondent’s audits, petitioners’                 
          administrative appeals, and the litigation of these and related             
          cases,2  petitioners made a number of substantial advance                   
          payments to respondent of taxes and of interest with respect to             
          each of the tax deficiencies determined by respondent against               
          petitioners for 1979 through 1985.                                          
               As of the January 1, 1995, effective date of the above GATT            
          amendment to section 6621(a)(1), with respect to each of the                
          years 1979 through 1985, petitioners had received from respondent           
          refunds of tax overpayments far in excess of $10,000, and                   
          petitioners still had outstanding with respondent overpayments of           
          tax in excess of $10,000.                                                   
               After the litigation and after settlement between the                  
          parties of many issues, all underlying tax issues relating to the           
          Federal income taxes of petitioners for 1979 through 1985 have              

               2  See, e.g., Exxon Corp. v. Commissioner, T.C. Memo. 1993-            
          616, affd. sub nom. Texaco, Inc. v. Commissioner, 98 F.3d 825               
          (5th Cir. 1996) (involving the allocation of profits from sales             
          of Saudi Arabian crude oil); Exxon Corp. v. Commissioner, 102               
          T.C. 721 (1994) (involving the computation of percentage                    
          depletion relating to the sale of natural gas); Exxon Corp. v.              
          Commissioner, T.C. Memo. 1999-247 (involving the deductibility of           
          interest relating to contested tax deficiencies); Exxon Corp. v.            
          Commissioner, 113 T.C. 338 (1999) (involving the credibility of             
          petroleum revenue tax paid to the United Kingdom); Exxon Mobil              
          Corp. v. Commissioner, 114 T.C. 293 (2000) (involving the                   
          deductibility of estimated dismantlement, removal, and restora-             
          tion costs relating to the Prudhoe Bay, Alaska, oil field).                 

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