Gulf Oil Corp. v. Commissioner
United States Tax Court
Petitioner obtained one-half of the rights to the Kuwait Concession in 1951 entitling it to engage in exploration, development, production, transportation, and marketing of Kuwaiti crude oil.
Read the full summary
Petitioner obtained one-half of the rights to the Kuwait Concession in 1951 entitling it to engage in exploration, development, production, transportation, and marketing of Kuwaiti crude oil. Portions of petitioner's interest were nationalized by Kuwait in 1973 and 1974. The final 20-percent ownership interest of petitioner was nationalized by Kuwait in 1975. The Nationalization Agreement, which had to be approved by the National Assembly of Kuwait, provided that petitioner would be paid $ 25,250,000, an amount equal to the book value of the physical assets excluding the value of the…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, by motion granted on November 10, 1983, agreed that certain issues would be severed and tried at a special trial session, which was held at Dallas, Texas.
One of the group of issues tried was designated by the parties as the “Kuwait Nationalization.” This requires the resolution of three issues: (1) Whether the value of the discount to be received under the crude…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. AndersonSupreme Court of the United States · 1926
- Gibson Products Co. Kell Blvd. v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Craft v. CommissionerUnited States Tax Court · 1977
- Ciaio v. CommissionerUnited States Tax Court · 1967
8 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1987
- Groetzinger v. CommissionerUnited States Tax Court · 1986
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
- Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1986
9 more not listed; retrieve them via the Exa API.