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
UNION TEXAS INTERNATIONAL CORPORATION, f.k.a. UNION TEXAS PETROLEUM CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. UNION TEXAS PETROLEUM ENERGY CORPORATION SUCCESSOR BY MERGER TO UNION TEXAS PETROLEUM CORPORATION, f.k.a. UNION TEXAS PROPERTIES CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Union Tex. Int'l Corp. v. Commissioner
Tax Ct. Dkt. No. 15182-94. Docket No. 15183-94
United States Tax Court
110 T.C. 321; 1998 U.S. Tax Ct. LEXIS 25; 110 T.C. No. 25;
May 21, 1998, Filed
Decisions will be entered under Rule 155.
R and P's predecessor, NP,…
2Cases cited27 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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