Gulf Oil Corp. v. Commissioner
United States Tax Court
In 1973, P and Iran executed an agreement for the exploration, production, refining, and sale of Iranian oil and gas. Under the agreement, P paid for a pro rata share of the costs of operation, advanced funds for capital, and received credits against future purchases of oil and gas from Iran for prior investments made by P in the Iranian oil fields. All of the payments or credits to be received by P were repayable solely from production of oil and gas.
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In 1973, P and Iran executed an agreement for the exploration, production, refining, and sale of Iranian oil and gas. Under the agreement, P paid for a pro rata share of the costs of operation, advanced funds for capital, and received credits against future purchases of oil and gas from Iran for prior investments made by P in the Iranian oil fields. All of the payments or credits to be received by P were repayable solely from production of oil and gas. P paid income taxes to Iran in the taxable year 1975. Held: P held an economic interest in the oil and gas in place for taxable years 1974 and…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, by motion granted on November 10, 1983, agreed that certain issues would be severed and tried at a special trial session which was held at Dallas, Texas.
One of the issues tried was designated by the parties as the “Iranian Foreign Tax Credit” issue. This requires the resolution of two issues relating to petitioner’s business operations in Iran during the taxable…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Palmer v. BenderSupreme Court of the United States · 1932
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Anderson v. HelveringSupreme Court of the United States · 1940
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
7 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1987
- Deskins v. CommissionerUnited States Tax Court · 1986
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
18 more not listed; retrieve them via the Exa API.