TEXACO INC. & SUBSIDIARIES v. COMMISSIONER

Docket No. 24855-89.

101 T.C. 571 (1993)

TEXACO INC. AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 15, 1993.


Attorney(s) appearing for the Case

Buford P. Berry, Emily A. Parker, Dennis J. Grindinger, and R. David Wheat, for petitioners.

Val J. Albright, Victoria J. Sherlock, and James E. Archie, for respondent.


WHITAKER, Judge:

A notice of deficiency for the years 1979, 1980, 1981, and 1982 was issued by respondent and was timely mailed to petitioners on July 31, 1989. Petitioners timely filed a petition herein contesting the deficiencies in tax determined by the Commissioner and claiming a refund of certain income tax overpayments plus interest as allowed by law. The issue for decision is the definition of "tar sands" for purposes of section 44D(c)(1)(A).

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