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STANDARD OIL CO. v. COMMISSIONER

Docket No. 5319-76.

77 T.C. 349 (1981)

STANDARD OIL COMPANY (INDIANA), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 12, 1981.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Richard M. Roberts, and William H. Bradford, Jr., for the petitioner.

Seymour I. Sherman and Robert R. Rubin, for the respondent.

GOFFE, Judge:

The Commissioner determined deficiencies in petitioner's Federal income tax for its taxable years ending December 31 of 1970 and 1971 in the respective amounts of $7,402,139.81 and $6,372,883.57. Petitioner moved, on the basis of our decision in Standard Oil Co. (Indiana) v. Commissioner, 68 T.C. 325 (1977), for summary judgment as to those deductions for intangible drilling and development costs (herein...

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