He launched the biggest proxy battle in business history when he tried to gain control of five seats on the board of directors, but he was ultimately defeated in a June 1988 shareholders' election. Chevron has since grown to become one of the world's largest multinational oil and gas industry companies, with operations in about 200 countries. Petitioners’ proposed definition of tar sands describes a highly viscous hydrocarbon that “could not be economically produced through a well using only primary recovery methods.” Alternatively, respondent’s proposed definition of tar sands describes a highly viscous hydrocarbon that is “not recoverable in its natural state by conventional oil well production methods including currently used enhanced recoveryPage 578 In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any such organizations, trades, or businesses. The 1979 pricing requirements were authorized by the King and issued by Minister Yamani on behalf of the Saudi government as mandatory restrictions. Secondary recovery methods involve injecting gas and/or water into wells as a means of supplying additional reservoir energy. [fn7] Petitioners concurrently assert that we should adopt the definition of tar sands promulgated in December 1980 by the Department of Energy’s Office of Oil and Natural Gas, Resource Applications.
The House andPage 577 44D was enacted; we are not persuaded that Congress intended to utilize the specific centipoise figure (10,000) contained therein. Jonathan S. Cohen, U.S. Department of Justice, Washington, DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, Loretta Argrett, Asst. The Tax Court supported this conclusion with a number of factual findings, including the following: 1. Overproduction, economic recession, and low prices plagued the oil industry in the early 1930s. For purposes of title I, crude oil included heavy oil and incremental tertiary oil but did not include synthetic petroleum such as oil produced from tar sands.
During the 1950s and 1960s Texaco concentrated on expanding its global refining and marketing operations. According to the latest filing with the SEC on September 16, 2019, Pierre R. Breber, Vice President and CFO of Chevron, owns 33,977 shares and is the fourth-largest individual shareholder, while Michael K. Wirth, the current chairman, owns 33,750 shares, and is the fifth-largest individual shareholder. § 1.482-1(b) (1) (1971)). Again the deciding issue was one of control: "Because Spanish law prohibited royalty payments, [the controlling company] could not exercise the control that § 482 contemplates, and allocation under § 482 is inappropriate." August 12, 2020. With the funds generated through these moves, Texaco could now increase its budget for overseas exploration and production. will encourage the development of these resources by decreasing the cost of their production relative to the price of imported oil. Because the sales price of the crude is governed by Letter 103/z, Texaco did not have the power to control the sales price of the oil. Petitioners did not claim that they were entitled to any Federal income tax credits pursuant to section 44D on any original (or amended) Federal income tax returns filed with respondent for the taxablePage 573 Id. Our editors will review what you’ve submitted and determine whether to revise the article. After raising $3 million, they reorganized their venture as The Texas Company. 44D(d)(6). TEXACO INC. SUBSIDIARIES v. COMM’R, 101 T.C. From early 1979 through late 1981, Saudi Arabia permitted Texaco and the other Aramco participants to buy Saudi Arabian crude oil at below market prices. While The Texas Corporation promoted its products and services at home, it undertook vigorous expansion abroad.
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