GULF OIL CORP. v. COMMISSIONER

Docket No. 22499-82.

87 T.C. 324 (1986)

GULF OIL CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 11, 1986.


Attorney(s) appearing for the Case

J. Waddy Bullion, Emily A. Parker, Sean T. Crimmins, Buford P. Berry, J. Y. Robb III, and Margaret S. Alford, for the petitioner.

Raymond L. Collins and William B. Lowrance, for the respondent.


GOFFE, Judge:

The Commissioner determined deficiencies in petitioner's Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, with the approval of the Court, agreed that certain issues would be severed and tried at a special trial session which was held at Dallas, Texas.

One of the issues to be tried was designated by the parties as the "Intangible...

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