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PHILLIPS PETROLEUM CO. v. COMMISSIONER

Docket No. 34019-87.

97 T.C. 30 (1991)

PHILLIPS PETROLEUM CO. AND AFFILIATED SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 3, 1991.

Attorney(s) appearing for the Case

Stephen D. Gardner, John Hartje, Ann-Elizabeth Purintun, and Carolyn J. Schwarz, for the petitioner.

Val J. Albright, Stephen C. Coen, and Martin Van Brauman, for the respondent.

KÖRNER, Judge:

This case is presently before the Court on the parties' cross-motions for partial summary judgment, submitted pursuant to Rule 121.1 At issue is the proper source and character of Phillips Petroleum Co.'s (hereinafter Phillips) income from certain sales of liquefied natural gas (LNG). Resolution of this issue initially requires that we determine whether section 1.863-1(b), Income Tax Regs., is a valid regulation...

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