Legal Opinion

Exxon Corp. v. Commissioner

United States Tax Court

Decided December 22, 1993No. Docket Nos. 18618-89, 24855-89, 18432-90Unpublished

Held: A Saudi crude oil resale pricing restriction in effect during a period in which Saudi crude was priced below other comparable crudes prohibited the sale of Saudi crude oil for an amount in excess of the Saudi official selling price, and petitioners complied with the restriction; consequently, respondent is precluded from allocating profits purportedly attributable to such excess from petitioners' refining subsidiaries to petitioners' offtakers pursuant to either sec.…

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Held: A Saudi crude oil resale pricing restriction in effect during a period in which Saudi crude was priced below other comparable crudes prohibited the sale of Saudi crude oil for an amount in excess of the Saudi official selling price, and petitioners complied with the restriction; consequently, respondent is precluded from allocating profits purportedly attributable to such excess from petitioners' refining subsidiaries to petitioners' offtakers pursuant to either sec. 61, I.R.C., or sec. 482, I.R.C.Commissioner v. First Security Bank, 405 U.S. 394 (1972); Procter & Gamble Co. v.…

1Opinion of the Court

EXXON CORPORATION AND AFFILIATED COMPANIES, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Exxon Corp. v. Commissioner

Docket Nos. 18618-89, 24855-89, 18432-90

United States Tax Court

T.C. Memo 1993-616; 1993 Tax Ct. Memo LEXIS 629; 66 T.C.M. (CCH) 1707;

December 22, 1993, Filed

Held: A Saudi crude oil resale pricing restriction in effect during a period in which Saudi crude was priced below other comparable crudes prohibited the sale of Saudi crude oil for an amount in excess of the Saudi official selling price, and petitioners complied with the restriction; consequently,…

2Cases cited25 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Republic of Argentina v. Weltover, Inc.Supreme Court of the United States · 1992
  4. Saudi Arabia v. NelsonSupreme Court of the United States · 1993
  5. Poe v. SeabornSupreme Court of the United States · 1930

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