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  5. 914 F.2d 396 (1990)
 

GULF OIL CORP. v. C.I.R.

Nos. 89-2049, 89-2050.

914 F.2d 396 (1990)

GULF OIL CORPORATION, Appellant in No. 89-2049 v. COMMISSIONER OF INTERNAL REVENUE. COMMISSIONER OF INTERNAL REVENUE, Appellant in No. 89-2050 v. GULF OIL CORPORATION.

United States Court of Appeals, Third Circuit.

Decided September 11, 1990.

Attorney(s) appearing for the Case

J.W. Bullion (argued), Emily A. Parker (argued), Thompson & Knight, Dallas, Tex., for Gulf Oil Corp.

Brian C. Griffin, Acting Asst. Atty. Gen., Gary R. Allen, Ann Belanger Durney, David I. Pincus (argued), Charles Bricken (argued), John A. Dudeck, Jr., Tax Div., Dept. of Justice, Washington, D.C., for C.I.R.

Before SLOVITER and MANSMANN, Circuit Judges, and THOMPSON, District Judge.

OPINION OF THE COURT

MANSMANN, Circuit Judge.

Gulf Oil Corporation and the Commissioner of Internal Revenue cross-appeal several decisions of the U.S. Tax Court involving Gulf's corporate tax liability for tax years 1974 and 1975.

Gulf, both directly and through its foreign subsidiaries and affiliates, explores, develops, produces, purchases and transports crude oil and natural gas world-wide, and manufactures, transports and markets petroleum products...

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