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SOUTHWESTERN ENERGY CO. & SUBS. v. COMMISSIONER

Docket No. 772-91.

100 T.C. 500 (1993)

SOUTHWESTERN ENERGY COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 1, 1993.

Attorney(s) appearing for the Case

Neal R. Pendergraft, E.J. Ball, and Kenneth R. Mourton, for petitioner.

Jeffry J. Erney, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined income tax deficiencies against petitioner for 1985 and 1986 in the amounts of $306,283.10 and $205,922.68, respectively. Petitioner is a group of consolidated corporations consisting of a parent, Southwestern Energy Co. (SW Energy), and subsidiaries which had filed consolidated returns on the accrual basis for those years. Petitioner's principal place of business when the petition herein was filed...

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