Phillips Petroleum Co. v. Commissioner
United States Tax Court
Ps, through their consolidated domestic subsidiary, extracted oil and gas from the Norwegian Continental Shelf in the North Sea, under a royalty license which they held from the Kingdom of Norway. Ps also paid charges to Norway based on the income derived from sales of these products, under three different Norwegian acts of its Parliament. Held, these three Norwegian charges were taxes, and were income or excess profits taxes within the meaning of sec. 901, I.R.C.
1Opinion of the Court
Korner, Judge:
By statutory notice of deficiency dated July 10, 1991, respondent determined deficiencies in the Federal income tax of Phillips Petroleum Co. and its affiliated subsidiaries (hereinafter Phillips or petitioners) for the taxable years 1979 through 1982 as follows:
Year Deficiency
1979 . $59,029,820
1980 . 61,528,138
1981 . 47,572,045
1982 . 5,536,203
All statutory references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, except as otherwise noted. After concessions and the severance of…
2Cases cited35 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- United States v. CartwrightSupreme Court of the United States · 1973
- Parker v. CommissionerUnited States Tax Court · 1986
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
30 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
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- Texasgulf, Inc. v. CommissionerUnited States Tax Court · 1996
- PPL Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 2010
- PPL Corp. v. CommissionerCourt of Appeals for the Third Circuit · 2011
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