Exxon Corp. v. United States

OPINION

REGINALD W. GIBSON, Senior Judge.

INTRODUCTION

In this federal income tax refund case, plaintiff Exxon Corporation and its consolidated subsidiaries seek to recover the sum of $172,584,915.83, plus interest thereon as provided by law. Said amount represents Exxon’s alleged overpayment of federal corporate income taxes in the amount of $57,-704,527 and assessed interest in the amount of $114,880,388.83 for its taxable year ended December 31, 1975. At issue is Exxon’s claimed entitlement to percentage depletion deductions, pursuant to Internal Revenue Code §§ 611, 613, and 613A,1 relating…