Shell Oil Co. v. Commissioner
United States Tax Court
In Shell Oil Co. v. Commissioner, 89 T.C. 371 (1987), the Commissioner determined deficiencies in petitioner's windfall profit tax for the taxable quarters ended Mar. 31, 1980, June 30, 1980, Sept. 30, 1980, and Dec. 31, 1980, and alternatively, for the taxable year 1980. The parties disagreed over the attribution and allocation of certain expenses for the calculation of the taxable income from petitioner's oil and gas properties for purposes of the windfall profit tax net…
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In Shell Oil Co. v. Commissioner, 89 T.C. 371 (1987), the Commissioner determined deficiencies in petitioner's windfall profit tax for the taxable quarters ended Mar. 31, 1980, June 30, 1980, Sept. 30, 1980, and Dec. 31, 1980, and alternatively, for the taxable year 1980. The parties disagreed over the attribution and allocation of certain expenses for the calculation of the taxable income from petitioner's oil and gas properties for purposes of the windfall profit tax net income limitation. We interpreted the term "taxable income from the property" under sec. 613(a), I.R.C. 1954, and the…
1Opinion of the Court
SUPPLEMENTAL OPINION'
GOFFE, Judge:
On September 1, 1987, this Court filed its findings of fact and opinion in this case (89 T.C. 371 (1987)). Petitioner is an integrated oil company involved in all facets of the petroleum industry. The Commissioner determined deficiencies in petitioner’s windfall profit tax under section 49861 for the taxable quarters ended March 31, 1980, June 30, 1980, September 30, 1980, and December 31, 1980. Alternatively, the Commissioner determined a deficiency in petitioner’s windfall profit tax for the taxable year 1980. The parties disagreed over the attribution and…
2Cases cited6 opinions
- Bowers, Collector of Internal Revenue v. New York & Albany Lighterage Co. Same v. Seaman. Same v. FullerSupreme Court of the United States · 1927
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Page v. CommissionerUnited States Tax Court · 1986
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
1 more not listed; retrieve them via the Exa API.
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