Legal Opinion

Exxon Mobil Corp. v. Commissioner

United States Tax Court

Decided May 3, 2000No. 18618-89; No. 18432-90Published

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

EXXON MOBIL CORPORATION AND AFFILIATED COMPANIES, F.K.A. EXXON CORPORATION AND AFFILIATED COMPANIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Exxon Mobil Corp. v. Commissioner

No. 18618-89; No. 18432-90

United States Tax Court

114 T.C. 293; 2000 U.S. Tax Ct. LEXIS 26; 114 T.C. No. 20;

May 3, 2000, Filed

Exxon Corp.v Commissioner, T.C. Memo 1999-245, T.C. Memo 1999-247, 1999 Tax Ct. Memo LEXIS 283 (T.C., 1999)

Decisions will be entered under Rule 155.

HELD: For the years before the Court, $ 204 million

(reflecting petitioners' 22-percent share of a total $ 928

million) in estimated…

2Cases cited24 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  3. Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
  4. United States v. General Dynamics Corp.Supreme Court of the United States · 1987
  5. United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986

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