Exxon Mobil Corp. v. Commissioner
United States Tax Court
HELD: For the years before the Court, $ 204 million (reflecting petitioners' 22-percent share of a total $ 928 million) in estimated dismantlement, removal, and restoration (DRR) costs relating to fieldwide oil production equipment and facilities located in the Prudhoe Bay oil field on the North Slope of Alaska is not sufficiently fixed and definite to be accruable under the all-events test of sec. 1.461-1(a)(2), Income Tax Regs.
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HELD: For the years before the Court, $ 204 million (reflecting petitioners' 22-percent share of a total $ 928 million) in estimated dismantlement, removal, and restoration (DRR) costs relating to fieldwide oil production equipment and facilities located in the Prudhoe Bay oil field on the North Slope of Alaska is not sufficiently fixed and definite to be accruable under the all-events test of sec. 1.461-1(a)(2), Income Tax Regs. HELD, FURTHER, for the years before the Court, $ 24 million (reflecting petitioners' 22-percent share of a total $ 111 million) in estimated DRR costs relating…
1Opinion of the Court
Swift, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income taxes for the years 1979 through 1982 as follows:
Year Deficiency
1979 . $268,721,294
1980 . 2,898,174,073
1981 . 2,037,809,876
1982 . 1,599,495,218
After settlement of many issues and Court decisions on three issues,1 the primary issue remaining for decision is whether petitioners’ attempted accrual, for 1979 through 1982, of its $204 million share of $928 million in total estimated dismantlement, removal, and restoration (drr) costs relating to oil wells and to oil production equipment and…
2Cases cited23 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- United States v. General Dynamics Corp.Supreme Court of the United States · 1987
- United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986
18 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2006
- Chrysler Corp. v. CommissionerUnited States Tax Court · 2000
- Amergen Energy Co. v. United StatesUnited States Court of Federal Claims · 2013
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2011
- Anschutz Co. v. Comm'rUnited States Tax Court · 2006
8 more not listed; retrieve them via the Exa API.