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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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