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SCHLUMBERGER TECHNOLOGY CORP. v. U.S.

No. 98-20810.

195 F.3d 216 (1999)

SCHLUMBERGER TECHNOLOGY CORPORATION, also known as Sedco, Inc., Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

November 5, 1999.

Attorney(s) appearing for the Case

Bryant C. Boren, Jr. (argued), Stephen David Marcus, Cynthia Lee Dow, Baker & Botts, Dallas, TX, Benjamin Gladney Wells (argued), Houston, TX, for Plaintiff-Appellee.

Robert W. Metzler (argued), Richard Bradshaw Farber, U.S. Dept. of Justice, Texas Div., Washington, DC, for Defendant-Appellant.

Before REAVLEY, HIGGINBOTHAM and DENNIS, Circuit Judges.

PATRICK E. HIGGINBOTHAM, Circuit Judge:

This case concerns the time at which a taxpayer must accrue a foreign arbitral award as income. The district court held that an arbitral award need not be accrued until the time to appeal judicial confirmation of the award expires in the jurisdiction in which enforcement is sought. We AFFIRM.

I.

Sedco, Inc., now part of Schlumberger Technology Corp. (STC), entered a joint venture in 1966 with a company owned...

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