Legal Opinion

Phillips Petroleum Co. v. Commissioner

United States Tax Court

Decided March 9, 1995No. Docket No. 22608-91Published

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

Phillips Petroleum Company and Affiliated Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Phillips Petroleum Co. v. Commissioner

Docket No. 22608-91

United States Tax Court

104 T.C. 256; 1995 U.S. Tax Ct. LEXIS 13; 104 T.C. No. 12;

March 9, 1995, Filed

An order will be issued restoring this case to the general docket for resolution of the remaining issues.

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…

2Cases cited37 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. United States v. CartwrightSupreme Court of the United States · 1973
  3. Parker v. CommissionerUnited States Tax Court · 1986
  4. Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
  5. Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957

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