Exit. Mo, X0M-2
`Dieecez) Mis. 1508-390-00F
`
`Page 1 of 6
`HORST FRISCH
`
`INCORPORATED
`WaTERGATE OFFiCE BiILDING
`2600 VIRGINIA AVENUE, Nw, SUTTE 300
`WASHINGTON, BC 20037
`
`MANAGENG DIRECTORS Ma 202 /296-4005 Fax 202/296-4008
`
`DANIEL L. FRISCH
`
`BARBARA, L. ROLLINS0N
`
`. WILLLAM MORGAN
`T FOTT NEWLON
`TIOHAS E. METER
`LESLEY CAMERGH
`
`Education
`
`THOMAS HORST, Ph.D.
`
`B.A.. Amherst College, 1965
`M.A., Economics, University of Rochester, 1867
`Ph.D., Economics, University of Rochester, 1268
`
`Professional Experience
`
`1988+
`
`198588
`
`Managing Director, Horst Frisch Incorporated. Company provides
`economic consulting services to private and public sector clients in
`areas similar to those served since 1981. Major areas of recent
`work include transfer pricing of U.S. and foreign-based
`multinationals, other income tax analyses, and FERC regulation of
`oil pipelines in Alaska and the Lower 48,
`
`Director, International Tax Analysis, Deloitte Haskins & Sells.
`Trained and supervised staff of six professional economists to
`analyze transfer pricing and other intemational tax matters requiring
`economic analysis. Author of the Intemational Bureau of Fiscal
`Documentation loose-leal survey of transfer pricing rules for the
`United States. Testiied before Congressional tax-writing
`commitiees on the appropriate tax treatment of foreign exchange
`gains and losses and on the impact of the Tax Reform Act of 1986
`on the intemational compefitiveness of U.S.-based service
`industries, Designed and supervised development of
`comprehensive computer program to calculate and project DH&S
`corporate clients’ federal income tax liability (including complax
`foreign tax credit provisions) under Tax Reform Act of 1986 and
`subsequent law changes. Provided extensive and on-going advice
`to, and expert witness testimony for, the State of Alaska regarding
`oil pipeline tariff regulation and various state income tax issues.
`
`einaY BUULAORY QOALIHTE
`.--"R,mn_'?ff - b,
`
`MLEELE
`
`ney WA rl"'+:£ - L=
`
`AT
`
`e A
`
`
`
`
`
`
`
`
`1981-85
`
`1977-81
`
`1975-77
`
`1873-75
`
`Exh. Mo, X084-2
`Docket Mo 1508-390-002
`Fupe 2ol
`
`Principal, Taxecon Associates, Inc. Devoted considerable time to
`evaluating alternative proposals for out-of-court resolution of Trans
`Alaska Pipeline System (TAPS) tariff litigation; analyzed transfer
`pricing of goods, services, and intangibles; developed computer
`models of after-tax value of resource-extraction and manufacturing
`projects to various participants (owner-operators, governments,
`respurce owners, creditors, etc); evaluated economic
`consequences of allowing Eurobonds to be issued by U.S.
`companies through tax-haven finance subsidiaries; compared
`taxation of intermational income of commercial banks in the U.S,,
`U.K., France, Germany, and Japan.
`
`Director, Intemnational Tax Staff, Office of Tax Analysis, U.S.
`Treasury Department. Formulated 1980 Treasury Department
`proposals for taxing foreign cumency gains and losses. Actively
`involved in projects conceming transfer pricing rules; allocation of
`R&D, interest and other expenses against foreign income; foreign
`investment in U.5. real estate (drafted 1978 Treasury report to
`Congress), deduction of interest expense for U.S. branches of
`foreign banks (devised approach taken in section 882 regulations),
`taxation of U.S. banks by U.S. and foreign governments; criteria for,
`and limitations on, foreign tax credits allowed to U.5. taxpayers; tax
`treatment of “possessions corporations” (drafted first Treasury
`Report); taxation of actual and deemed dividends from foreign
`subsidiaries; and Domestic International Sales Corporations.
`Supervised staff of eight economists providing economic analysis of
`international tax issues. Worked closely with International Tax
`Counsel of the Treasury Department on legisiation, regulations, tax
`treaties, Congressional reports and other intemational tax matters.
`
`Associate Professor of International Economics at the Fletcher
`School of International Law and Diplomacy at Tufts University.
`Taught courses in international trade and Investment, international
`finance, microaconomics, econometrics, and introductory
`aconomics. Awarded and managed research contracts from the
`U.S. Treasury and Labor Depariments. Appointed by President
`Ford to the Presidential Commission on Intermnational Investment.
`
`Research Associate at the Brookings Institution, Washington, DC.
`Co-author of book on the impact of U.S. multinational corporations
`on the U.S. economy and foreign policy. Drafted chapters on
`Impact on U.S. exports, imports and balance of payments, antitrust
`issues, and income taxation. These chapters were specifically
`cited in several favorable book reviews.
`
`
`
`
`
`
`
`
`i
`
`Exth. Mo. X0k -2
`Docket Ho. [508-500-002
`
`Page 3 of 6
`
`1969-73 Assistant Professor of Economics at Harvard University. Taught
`graduate and undergraduate courses in intemnational trade and
`investment and intemational finance. Published book on
`international investment by U.S. food-processing companies and
`articles on intemational trade and investment in the American
`Economic Review and other leading economic journals.
`
`Books and Articles by Thomas Horst
`
`“Comparable Frofits Method,” in Eractical Guide to U.S, Transfer Pricing, Robert
`T. Cole, Editor, Tax Analysts, 2006,
`
`"Using Discount Rates to Adjust Transfer Prices Under Long-Term Agreements
`
`for Differences in Risk,” Tax Management Transfer Pricing Report, December 22,
`2004,
`
`*Comparable Profits Method,” in Practical Guide to U.S. Transfer Pricing, Robert
`T. Cole, Editor, Tax Analysts, 2001.
`
`"Practical Realities of Transfer Pricing Analysis," T Prici
`Movember-December 2000,
`
`"Ta:ahnn of Fmalgrl inmm& of Financm Sarvm Eumpanlu M
`
`cmr far Eapltal Fflrmaflun. 199?
`
`"Profit Split Method,” Tax Notes, July 19, 1983,
`
`“The Comparable Profits Method " Tax Notes, May 31, 1983,
`
`"Transfer Pricing in the United States”, in Hubert Hamaekers, Maurice H. Collins
`
`and Wilheimina A. Comello, eds., The Tax Treatment of Transfer Pricing,
`International Bureau of Fiscal Documentation, 1992,
`
`“Bausch & Lomb and the While Paper”, (with Daniel Frisch), Tax Notes. May 8,
`1888,
`
`"Royalties and Super Royalties”, Intemational Tax News, Deloitte Haskins &
`Sells Intermational, September 1987,
`
`"The Case for Normalizing the Excess Tax Reserves of Public Utilities” (with Emil
`M. Sunley), Tax Notes, June 29, 1987.
`
`"Foreign Exchange Gains and Losses: What are the Issues?", Tax Notes,
`September 16, 1885,
`
`
`
`
`
`
`
`
`Exh. No. XOM-2
`Deechoet Mo, ES08-To0u000
`Paged of &
`
`"International Aspects of Basic Tax Reform" (with Gary Hufbauer) in Charles
`
`Walker, ed., New Directions in Federal Tax Policy for the 1980's, American
`Council for Capital Formation, 1983.
`
`"Some Issues in the Calculation and Uses of Effective Corporation Income Tax
`", Tax Motes, November 1, 1982,
`
`"Tmtallnn nf Intaflut-nnal Income of Gnman:lal Banhu‘ in Gcnw Hufbauer, ed.,
`i 280's Int&mnmnal
`Law Tnsfih.rt& Ge-nrgatnmm Llnhramihr Luw E&rrl:ur, Washlngtnn. I:Ir: 1881.
`
`“A Note on the Oplimal Taxation of Intemnational Investment Income”, Quartery
`Journal of Economics. June 1980.
`
`ftinationals and Interests (with C. Fred Bergsten and
`Theodore H. Moran), The Brockings Institution, 1978.
`
`Unj ngdom and Jacen. Mational Planhing. Associstion
`Committee on Changing International Realities, 1877,
`
`;;;:;Tm'imn Taxation of Multinational Firms®, American Economic Review, June
`
`"American Multinationals and the U.S. Economy”, American Economic Review,
`May 1978,
`
`“The Theory of the Fim", in John H. U'unmg&d Economic_Analysis of
`_Mm&mmefilm&mmn 1974,
`
`At Home Abroad: A Study of the Domestic and Foreign Operations of the
`American Food-Processing Industry, The Ballinger Publishing Company, 1873,
`
`“The Simple Analytics of Multinational Firm Behavior”, in Michael B. Connolly and
`
`Alexander K. Swoboda, eds., [ntemational Trade and Money, George Allen &
`Unwin, 1873,
`
`"Firm and Industry Determinants of the Decision to Invest Abroad”, Review of
`Economics and Statistics, August 1972.
`
`“The Industrial Composition of U.S. Exports and Subsidiary Sales to the
`Canadian Market", American Economic Review, March 1872,
`
`“The Theory of the Multinational Firm: Optimal Behavior Under Different Tariff
`and Tax Rates”, Journal of Political Economy, October 1971.
`
`
`
`
`
`
`
`
`| O T I |
`
`1
`
`Exh. Na. X2
`Deosclort Mo 150E-FR0-002
`
`Page 5 of &
`
`Expert Testimony of Thomas Horst
`Transfer Pricing
`
`The Perkin Elmer Corporafion and Subsidiaries v. Commissioner of [nfemal
`Hevenue, United States Tax Court, Docket No. 28880-89, 1991,
`
`The Seagate Technology inc. and Consolidated Subsidiaries v. Commissioner of
`Infernal Revenue, United States Tax Court, Docket No. 11680-80, 1891.
`
`National Semiconductor Corporation v. Commissioner of Infermal Revenue,
`United States Tax Court, Docket Nos. 4754-89 and 8031-90, 1982.
`
`Altama Delta Corporation v. Commissioner of Infermal Revenue, United States
`Tax Court, Docket No. 15083-92, 1954,
`
`In the Matter of Ford Motor Company of Canada, Limited, Superior Court of
`Justice (Ontario, Canada), Commerclal List Court File No. 88-3075, January 22,
`2004,
`
`Qil Pipeline Regulation
`
`Trans-Alaska Pipaline System v. The Stale of Alaska, Federal Enargy Regulatory
`Commisgsion, 33 FERC (CCH) Y 61,064 (1885), 35 FERC (CCH) 1 61,425 (1888).
`
`Kuparuk Transportalion Company v. The Stale of Alasks, Federal Energy
`Regulatory Commission, Docket Mos. 1595-9-000, ORB85-1-000, ORS0-1-000.
`
`Endicott Pipeline Company v. The State of Alaska, Federal Energy Regulatory
`Commission, Docket No. I1S87-35-000.
`
`llj-lmmar Canada Inc. v. Monireal Pipe Line Lid. (19880), 74 O.R. (2d) 136
`(H.C.J.)
`
`Amerada Hess Pipeline Corporalion v. The Slate of Alaska, Federal Energy
`Regulatory Commission, Docket No. 1592-3-000, af al.
`
`fgifi L.P., Federal Energy Regulatory Commission, Dacket Nos. OR92-8-000
`
`Amerada Hess Pipefine Corporalion, ef al. v. The Siale of Alaska, Federal
`Energy Regulatory Commission, Docket Nos, 1594-10-002 et al., and Alaska
`Public Utilittes Commission, Docket No. P-84-1, 1996,
`
`
`
`
`
`
`
`
`(N DA N
`
`Exh Mo X(id-1
`Deaclet Ha, E504-150-002
`
`Page & ol 6
`
`ARCO Products Company, et al, v. SFPP, L P., Public Utilities Commission of
`the State of California, Case No, 97-04-025.
`
`SFPP, LP., Federal Energy Regulatory Commission, Docket Nos. OR56-2-000
`etal
`
`Composifion of Proxy Groups for Defermining Gas and Qil Pipeline Refum on
`Equily, Federal Energy Regulatory Commission, Docket No. PLO7-2-000.
`
`Cook Inlet Pipe Line Company v. The State of Alaska, Regulatory Commission of
`Alaska, Docket Nos. P-07-5, P-08-3, P-08-7. '
`
`Kuparuk Transportation Company v. The State of Alaska, Regulatory
`Commission of Alaska, Docket No. P-08.
`
`SFFPP, LP., Federal Energy Regulatory Commission, Docket No. 1508-380-002.
`
`Other Matters
`
`Aflantic Richfield Co. v. The Stale of Alaska, 705 P.2d. 418 1985, Appeal
`Dismissed, 474 U.S. 1043.
`
`Judge Temy J. Hafter, Jr. v. The Unifed Stafes of America, Docket No. T05-88C,
`United States Court of Federal Claims, in Support of Plaintiffs Motion for
`Summary Judgment, November 12, 1956.
`
`ASA Investerings Partnership, AlliedSignal Inc., Tax Mafters Pariner v.
`Commissioner of Infemal Revenue, United States Tax Court, Docket No. 27320-
`86, 1988,
`
`Sun Company and Subsidiaries v. Commissioner of Infemal Revenue, United
`States Tax Court, Docket No. 19631-87.
`
`
`
`
`
`
`
`
`
`Dieecez) Mis. 1508-390-00F
`
`Page 1 of 6
`HORST FRISCH
`
`INCORPORATED
`WaTERGATE OFFiCE BiILDING
`2600 VIRGINIA AVENUE, Nw, SUTTE 300
`WASHINGTON, BC 20037
`
`MANAGENG DIRECTORS Ma 202 /296-4005 Fax 202/296-4008
`
`DANIEL L. FRISCH
`
`BARBARA, L. ROLLINS0N
`
`. WILLLAM MORGAN
`T FOTT NEWLON
`TIOHAS E. METER
`LESLEY CAMERGH
`
`Education
`
`THOMAS HORST, Ph.D.
`
`B.A.. Amherst College, 1965
`M.A., Economics, University of Rochester, 1867
`Ph.D., Economics, University of Rochester, 1268
`
`Professional Experience
`
`1988+
`
`198588
`
`Managing Director, Horst Frisch Incorporated. Company provides
`economic consulting services to private and public sector clients in
`areas similar to those served since 1981. Major areas of recent
`work include transfer pricing of U.S. and foreign-based
`multinationals, other income tax analyses, and FERC regulation of
`oil pipelines in Alaska and the Lower 48,
`
`Director, International Tax Analysis, Deloitte Haskins & Sells.
`Trained and supervised staff of six professional economists to
`analyze transfer pricing and other intemational tax matters requiring
`economic analysis. Author of the Intemational Bureau of Fiscal
`Documentation loose-leal survey of transfer pricing rules for the
`United States. Testiied before Congressional tax-writing
`commitiees on the appropriate tax treatment of foreign exchange
`gains and losses and on the impact of the Tax Reform Act of 1986
`on the intemational compefitiveness of U.S.-based service
`industries, Designed and supervised development of
`comprehensive computer program to calculate and project DH&S
`corporate clients’ federal income tax liability (including complax
`foreign tax credit provisions) under Tax Reform Act of 1986 and
`subsequent law changes. Provided extensive and on-going advice
`to, and expert witness testimony for, the State of Alaska regarding
`oil pipeline tariff regulation and various state income tax issues.
`
`einaY BUULAORY QOALIHTE
`.--"R,mn_'?ff - b,
`
`MLEELE
`
`ney WA rl"'+:£ - L=
`
`AT
`
`e A
`
`
`
`
`
`
`
`
`1981-85
`
`1977-81
`
`1975-77
`
`1873-75
`
`Exh. Mo, X084-2
`Docket Mo 1508-390-002
`Fupe 2ol
`
`Principal, Taxecon Associates, Inc. Devoted considerable time to
`evaluating alternative proposals for out-of-court resolution of Trans
`Alaska Pipeline System (TAPS) tariff litigation; analyzed transfer
`pricing of goods, services, and intangibles; developed computer
`models of after-tax value of resource-extraction and manufacturing
`projects to various participants (owner-operators, governments,
`respurce owners, creditors, etc); evaluated economic
`consequences of allowing Eurobonds to be issued by U.S.
`companies through tax-haven finance subsidiaries; compared
`taxation of intermational income of commercial banks in the U.S,,
`U.K., France, Germany, and Japan.
`
`Director, Intemnational Tax Staff, Office of Tax Analysis, U.S.
`Treasury Department. Formulated 1980 Treasury Department
`proposals for taxing foreign cumency gains and losses. Actively
`involved in projects conceming transfer pricing rules; allocation of
`R&D, interest and other expenses against foreign income; foreign
`investment in U.5. real estate (drafted 1978 Treasury report to
`Congress), deduction of interest expense for U.S. branches of
`foreign banks (devised approach taken in section 882 regulations),
`taxation of U.S. banks by U.S. and foreign governments; criteria for,
`and limitations on, foreign tax credits allowed to U.5. taxpayers; tax
`treatment of “possessions corporations” (drafted first Treasury
`Report); taxation of actual and deemed dividends from foreign
`subsidiaries; and Domestic International Sales Corporations.
`Supervised staff of eight economists providing economic analysis of
`international tax issues. Worked closely with International Tax
`Counsel of the Treasury Department on legisiation, regulations, tax
`treaties, Congressional reports and other intemational tax matters.
`
`Associate Professor of International Economics at the Fletcher
`School of International Law and Diplomacy at Tufts University.
`Taught courses in international trade and Investment, international
`finance, microaconomics, econometrics, and introductory
`aconomics. Awarded and managed research contracts from the
`U.S. Treasury and Labor Depariments. Appointed by President
`Ford to the Presidential Commission on Intermnational Investment.
`
`Research Associate at the Brookings Institution, Washington, DC.
`Co-author of book on the impact of U.S. multinational corporations
`on the U.S. economy and foreign policy. Drafted chapters on
`Impact on U.S. exports, imports and balance of payments, antitrust
`issues, and income taxation. These chapters were specifically
`cited in several favorable book reviews.
`
`
`
`
`
`
`
`
`i
`
`Exth. Mo. X0k -2
`Docket Ho. [508-500-002
`
`Page 3 of 6
`
`1969-73 Assistant Professor of Economics at Harvard University. Taught
`graduate and undergraduate courses in intemnational trade and
`investment and intemational finance. Published book on
`international investment by U.S. food-processing companies and
`articles on intemational trade and investment in the American
`Economic Review and other leading economic journals.
`
`Books and Articles by Thomas Horst
`
`“Comparable Frofits Method,” in Eractical Guide to U.S, Transfer Pricing, Robert
`T. Cole, Editor, Tax Analysts, 2006,
`
`"Using Discount Rates to Adjust Transfer Prices Under Long-Term Agreements
`
`for Differences in Risk,” Tax Management Transfer Pricing Report, December 22,
`2004,
`
`*Comparable Profits Method,” in Practical Guide to U.S. Transfer Pricing, Robert
`T. Cole, Editor, Tax Analysts, 2001.
`
`"Practical Realities of Transfer Pricing Analysis," T Prici
`Movember-December 2000,
`
`"Ta:ahnn of Fmalgrl inmm& of Financm Sarvm Eumpanlu M
`
`cmr far Eapltal Fflrmaflun. 199?
`
`"Profit Split Method,” Tax Notes, July 19, 1983,
`
`“The Comparable Profits Method " Tax Notes, May 31, 1983,
`
`"Transfer Pricing in the United States”, in Hubert Hamaekers, Maurice H. Collins
`
`and Wilheimina A. Comello, eds., The Tax Treatment of Transfer Pricing,
`International Bureau of Fiscal Documentation, 1992,
`
`“Bausch & Lomb and the While Paper”, (with Daniel Frisch), Tax Notes. May 8,
`1888,
`
`"Royalties and Super Royalties”, Intemational Tax News, Deloitte Haskins &
`Sells Intermational, September 1987,
`
`"The Case for Normalizing the Excess Tax Reserves of Public Utilities” (with Emil
`M. Sunley), Tax Notes, June 29, 1987.
`
`"Foreign Exchange Gains and Losses: What are the Issues?", Tax Notes,
`September 16, 1885,
`
`
`
`
`
`
`
`
`Exh. No. XOM-2
`Deechoet Mo, ES08-To0u000
`Paged of &
`
`"International Aspects of Basic Tax Reform" (with Gary Hufbauer) in Charles
`
`Walker, ed., New Directions in Federal Tax Policy for the 1980's, American
`Council for Capital Formation, 1983.
`
`"Some Issues in the Calculation and Uses of Effective Corporation Income Tax
`", Tax Motes, November 1, 1982,
`
`"Tmtallnn nf Intaflut-nnal Income of Gnman:lal Banhu‘ in Gcnw Hufbauer, ed.,
`i 280's Int&mnmnal
`Law Tnsfih.rt& Ge-nrgatnmm Llnhramihr Luw E&rrl:ur, Washlngtnn. I:Ir: 1881.
`
`“A Note on the Oplimal Taxation of Intemnational Investment Income”, Quartery
`Journal of Economics. June 1980.
`
`ftinationals and Interests (with C. Fred Bergsten and
`Theodore H. Moran), The Brockings Institution, 1978.
`
`Unj ngdom and Jacen. Mational Planhing. Associstion
`Committee on Changing International Realities, 1877,
`
`;;;:;Tm'imn Taxation of Multinational Firms®, American Economic Review, June
`
`"American Multinationals and the U.S. Economy”, American Economic Review,
`May 1978,
`
`“The Theory of the Fim", in John H. U'unmg&d Economic_Analysis of
`_Mm&mmefilm&mmn 1974,
`
`At Home Abroad: A Study of the Domestic and Foreign Operations of the
`American Food-Processing Industry, The Ballinger Publishing Company, 1873,
`
`“The Simple Analytics of Multinational Firm Behavior”, in Michael B. Connolly and
`
`Alexander K. Swoboda, eds., [ntemational Trade and Money, George Allen &
`Unwin, 1873,
`
`"Firm and Industry Determinants of the Decision to Invest Abroad”, Review of
`Economics and Statistics, August 1972.
`
`“The Industrial Composition of U.S. Exports and Subsidiary Sales to the
`Canadian Market", American Economic Review, March 1872,
`
`“The Theory of the Multinational Firm: Optimal Behavior Under Different Tariff
`and Tax Rates”, Journal of Political Economy, October 1971.
`
`
`
`
`
`
`
`
`| O T I |
`
`1
`
`Exh. Na. X2
`Deosclort Mo 150E-FR0-002
`
`Page 5 of &
`
`Expert Testimony of Thomas Horst
`Transfer Pricing
`
`The Perkin Elmer Corporafion and Subsidiaries v. Commissioner of [nfemal
`Hevenue, United States Tax Court, Docket No. 28880-89, 1991,
`
`The Seagate Technology inc. and Consolidated Subsidiaries v. Commissioner of
`Infernal Revenue, United States Tax Court, Docket No. 11680-80, 1891.
`
`National Semiconductor Corporation v. Commissioner of Infermal Revenue,
`United States Tax Court, Docket Nos. 4754-89 and 8031-90, 1982.
`
`Altama Delta Corporation v. Commissioner of Infermal Revenue, United States
`Tax Court, Docket No. 15083-92, 1954,
`
`In the Matter of Ford Motor Company of Canada, Limited, Superior Court of
`Justice (Ontario, Canada), Commerclal List Court File No. 88-3075, January 22,
`2004,
`
`Qil Pipeline Regulation
`
`Trans-Alaska Pipaline System v. The Stale of Alaska, Federal Enargy Regulatory
`Commisgsion, 33 FERC (CCH) Y 61,064 (1885), 35 FERC (CCH) 1 61,425 (1888).
`
`Kuparuk Transportalion Company v. The Stale of Alasks, Federal Energy
`Regulatory Commission, Docket Mos. 1595-9-000, ORB85-1-000, ORS0-1-000.
`
`Endicott Pipeline Company v. The State of Alaska, Federal Energy Regulatory
`Commission, Docket No. I1S87-35-000.
`
`llj-lmmar Canada Inc. v. Monireal Pipe Line Lid. (19880), 74 O.R. (2d) 136
`(H.C.J.)
`
`Amerada Hess Pipeline Corporalion v. The Slate of Alaska, Federal Energy
`Regulatory Commission, Docket No. 1592-3-000, af al.
`
`fgifi L.P., Federal Energy Regulatory Commission, Dacket Nos. OR92-8-000
`
`Amerada Hess Pipefine Corporalion, ef al. v. The Siale of Alaska, Federal
`Energy Regulatory Commission, Docket Nos, 1594-10-002 et al., and Alaska
`Public Utilittes Commission, Docket No. P-84-1, 1996,
`
`
`
`
`
`
`
`
`(N DA N
`
`Exh Mo X(id-1
`Deaclet Ha, E504-150-002
`
`Page & ol 6
`
`ARCO Products Company, et al, v. SFPP, L P., Public Utilities Commission of
`the State of California, Case No, 97-04-025.
`
`SFPP, LP., Federal Energy Regulatory Commission, Docket Nos. OR56-2-000
`etal
`
`Composifion of Proxy Groups for Defermining Gas and Qil Pipeline Refum on
`Equily, Federal Energy Regulatory Commission, Docket No. PLO7-2-000.
`
`Cook Inlet Pipe Line Company v. The State of Alaska, Regulatory Commission of
`Alaska, Docket Nos. P-07-5, P-08-3, P-08-7. '
`
`Kuparuk Transportation Company v. The State of Alaska, Regulatory
`Commission of Alaska, Docket No. P-08.
`
`SFFPP, LP., Federal Energy Regulatory Commission, Docket No. 1508-380-002.
`
`Other Matters
`
`Aflantic Richfield Co. v. The Stale of Alaska, 705 P.2d. 418 1985, Appeal
`Dismissed, 474 U.S. 1043.
`
`Judge Temy J. Hafter, Jr. v. The Unifed Stafes of America, Docket No. T05-88C,
`United States Court of Federal Claims, in Support of Plaintiffs Motion for
`Summary Judgment, November 12, 1956.
`
`ASA Investerings Partnership, AlliedSignal Inc., Tax Mafters Pariner v.
`Commissioner of Infemal Revenue, United States Tax Court, Docket No. 27320-
`86, 1988,
`
`Sun Company and Subsidiaries v. Commissioner of Infemal Revenue, United
`States Tax Court, Docket No. 19631-87.
`
`
`
`
`
`
`
`
`
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