Legal Opinion

Occidental Petroleum Corp. v. Commissioner

United States Tax Court

Decided May 24, 1984No. Docket No. 21969-80PublishedCited by 58 opinions

Ts' 1977 consolidated taxable income was computed by combining income from foreign sources and a loss from domestic sources. The domestic loss was a composite of a loss from domestic operations and three items of "tax preference" as defined in sec. 57(a), I.R.C. 1954. In respect of the income from foreign sources, Ts paid or were deemed to have paid foreign income taxes.

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Ts' 1977 consolidated taxable income was computed by combining income from foreign sources and a loss from domestic sources. The domestic loss was a composite of a loss from domestic operations and three items of "tax preference" as defined in sec. 57(a), I.R.C. 1954. In respect of the income from foreign sources, Ts paid or were deemed to have paid foreign income taxes. Ts elected to credit these taxes against their 1977 Federal income tax liability pursuant to sec. 901(a), thus eliminating such liability completely. In addition, Ts' foreign tax credits exceeded the amount of Federal income…

1Opinion of the Court

OPINION

Raum, Judge:

The Commissioner determined deficiencies and additions to tax against petitioners as follows:

Additions to tax, I.R.C. 1954

Year ■ Deficiency Sec. 6653(a). Sec. 6652(t) [sic]

1976 $14,340,296 $717,015

1977 20,356,133 1,017,807 $5,000

The deficiencies are based upon numerous adjustments, and the petitioners have raised some 91 separately enumerated allegations of error in the original petition. However, the parties have resolved all issues raised by those allegations of error, leaving for decision only the single issue raised in petitioners’ "First Amendment to Petition”: whether…

2Cases cited5 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Commissioner v. ConnellySupreme Court of the United States · 1949
  3. Occidental Petroleum Corp. v. United StatesUnited States Court of Claims · 1982
  4. International Tel. & Tel. Corp. etc. v. CommissionerUnited States Tax Court · 1981
  5. Corporation of America v. CommissionerUnited States Tax Court · 1945

3Cited by58 opinions

  1. Huntsberry v. CommissionerUnited States Tax Court · 1984
  2. Segel v. CommissionerUnited States Tax Court · 1987
  3. First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
  4. First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
  5. Bank One Corp. v. Comm'rUnited States Tax Court · 2003

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