Halliburton Company v. Commissioner of Internal Revenue

KAZEN, District Judge:

OPINION

The Commissioner of Internal Revenue (“Commissioner”) appeals from an adverse judgment by the Tax Court. Halliburton Co. v. Commissioner, 93 T.C. 758 (1989). The Commissioner raises two issues on appeal: (1) whether the Tax Court erroneously shifted the burden of proof from the taxpayer Halliburton Company (“Halliburton”) to Commissioner, and (2) whether the Tax Court’s conclusion that Halliburton had no reasonable prospect of recovering its expropriation loss as of the end of 1979 was clearly erroneous. Finding no reversible error, we affirm.

BACKGROUND

There is…