Exxon Corp. v. Commissioner
United States Tax Court
HELD: Petroleum revenue tax paid by petitioners to the United Kingdom was not paid in exchange for specific economic benefits and constitutes a creditable foreign tax under sec. 901, I.R.C.
1Opinion of the Court
Swift, Judge:
The issue for decision is whether Petroleum Revenue Tax (PRT) petitioners paid to the United Kingdom for 1983 through 1988 constitutes, for U.S. income tax purposes, a creditable income or excess profits tax under section 901 or a creditable tax in lieu thereof under section 903.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in question, and all Rule references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
The parties have stipulated numerous facts and admissibility of numerous exhibits. The…
2Cases cited5 opinions
- Texasgulf, Inc., and Subsidiaries, as Successor in Interest to Texasgulf, Inc. And Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1999
- Phillips Petroleum Co. v. CommissionerUnited States Tax Court · 1995
- Inland Steel Co. v. United StatesUnited States Court of Claims · 1982
- Bank of Am. Trust & Sav. Ass'n v. CommissionerUnited States Tax Court · 1974
- Texasgulf, Inc. v. CommissionerUnited States Tax Court · 1996
3Cited by11 opinions
- Exxon Mobil Corp. v. CommissionerUnited States Tax Court · 2000
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2006
- PPL Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 2010
- Exxon Corp. v. CommissionerUnited States Tax Court · 1999
- Exxon Corporation v. CommissionerUnited States Tax Court · 1999
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