Union Tex. Int'l Corp. v. Commissioner
United States Tax Court
R and P's predecessor, NP, executed a series of three Forms 872 for 1985. R did not know at the time of signing the Forms 872 that NP had merged with P and that NP no longer had authority to extend the period of limitations after Dec. 31, 1991. Effective Dec. 31, 1982, P's predecessor, OP, entered into an agency agreement with PR, a sister company, to process and sell propane for OP and NP to unrelated third parties.
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R and P's predecessor, NP, executed a series of three Forms 872 for 1985. R did not know at the time of signing the Forms 872 that NP had merged with P and that NP no longer had authority to extend the period of limitations after Dec. 31, 1991. Effective Dec. 31, 1982, P's predecessor, OP, entered into an agency agreement with PR, a sister company, to process and sell propane for OP and NP to unrelated third parties. OP and NP retained title to its propane until PR sold it to unrelated third parties. PR also sold its own propane to T, a related retailer. Ps assert that they should be…
1Opinion of the Court
OPINION
Parr, Judge:
In these consolidated cases, respondent determined the following deficiencies in windfall profit tax (wpt) for the taxable periods of 1983, 1984, and 1985, respectively: $3,471,045, $3,060,042, and $2,109,854. Respondent determined the deficiencies against Union Texas Petroleum International (International) for 1983 and 1984 and against Union Texas Petroleum Energy (Energy) for 1985. In their petitions, petitioners raised an issue pursuant to section 6512(b),1 claiming overpayments of WPT for the taxable periods of 1983, 1984, and 1985, respectively, in the following…
2Cases cited26 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Gregory v. HelveringSupreme Court of the United States · 1935
- Bull v. United StatesSupreme Court of the United States · 1935
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Stone v. WhiteSupreme Court of the United States · 1937
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3Cited by3 opinions
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- Indeck Energy Servs. v. Comm'rUnited States Tax Court · 2003
- Union Tex. Int'l Corp. v. CommissionerUnited States Tax Court · 1998