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EXXON CORPORATION v. COMMISSIONER

Docket Nos. 18618-89, 18432-90.

78 T.C.M. 165 (1999)

T.C. Memo. 1999-247

Exxon Corporation and Affiliated Companies v. Commissioner.

United States Tax Court.

Filed July 28, 1999.

Attorney(s) appearing for the Case

Robert L. Moore II, Washington, D. C., Frederick H. Robinson, Lisa F. Opoku, and Jordan L. Klingsberg, for the petitioners. Allan E. Lang, Christopher Fisher and Todd Ludeke, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

The issue for decision is the proper accrual, under the all-events test of section 461, of approximately $900 million in interest expense relating to increases in petitioners' Federal income taxes for the years 1972 through 1978.1

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

FINDINGS...

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