Legal Opinion

CanadianOxy Offshore Prod. Co. v. Commissioner

United States Tax Court

Decided April 29, 1993No. Docket No. 12102-89Published

P, an integrated producer of front-end oil, sold crude oil after Executive Order, No. 12,287, 3 C.F.R. 124 (1982), fully decontrolled crude oil and refined petroleum products. After decontrol, P did not recertify that the oil sold was tertiary incentive oil. P subtracted the credits against its windfall profit tax liability for the periods in question in accordance with sec. 4994(c)(2), I.R.C.

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P, an integrated producer of front-end oil, sold crude oil after Executive Order, No. 12,287, 3 C.F.R. 124 (1982), fully decontrolled crude oil and refined petroleum products. After decontrol, P did not recertify that the oil sold was tertiary incentive oil. P subtracted the credits against its windfall profit tax liability for the periods in question in accordance with sec. 4994(c)(2), I.R.C. Held: The Executive Order did not directly affect front-end oil as to integrated producers. Held, further, the front-end oil credit was similarly not terminated. Held, further, after decontrol (absent…

1Opinion of the Court

CANADIANOXY OFFSHORE PRODUCTION CO. (formerly: Cities Service Company and Cities Offshore Production Co.), Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

CanadianOxy Offshore Prod. Co. v. Commissioner

Docket No. 12102-89

United States Tax Court

100 T.C. 382; 1993 U.S. Tax Ct. LEXIS 25; 100 T.C. No. 25;

April 29, 1993, Filed

P, an integrated producer of front-end oil, sold crude oil after Executive Order, No. 12,287, 3 C.F.R. 124 (1982), fully decontrolled crude oil and refined petroleum products. After decontrol, P did not recertify that the oil sold was tertiary incentive oil. P…

2Cases cited5 opinions

  1. United States v. PtasynskiSupreme Court of the United States · 1983
  2. Union Oil Co. v. United States Department of EnergyTemporary Emergency Court of Appeals · 1982
  3. Elf Aquitaine, Inc. v. Placid Oil Co.District Court, D. Delaware · 1985
  4. Gary v. United StatesDistrict Court, D. Colorado · 1989
  5. CanadianOxy Offshore Prod. Co. v. CommissionerUnited States Tax Court · 1993

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