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UNION TEXAS INTL. CORP. v. COMMISSIONER

Docket Nos. 15182-94, 15183-94.

110 T.C. 321 (1998)

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

United States Tax Court.

Filed May 21, 1998.

Attorney(s) appearing for the Case

Jasper George Taylor III, Charles Washington Hall, William H. Caudill, and John B. Kinchen, for petitioners.

Sheri Wilcox, for respondent.

OPINION

PARR, Judge:

In these consolidated cases, respondent determined the following deficiencies in windfall profit tax (WPT) for the taxable periods of 1983, 1984, and 1985, respectively: $3,471,045, $3,060,042, and $2,109,854. Respondent determined the deficiencies against Union Texas Petroleum International (International) for 1983 and 1984 and against Union Texas Petroleum Energy (Energy) for 1985....

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