Sunoco’s $2.64 Million Tax Refund Was Properly Denied, NY Argues

A New York appeals court should reject a Sunoco LP subsidiary’s attempt to reduce the amount of income from oil transfers that’s taxable there, the state tax department argued.

At issue are “buy/sell transactions” where Sunoco would buy inventory from another oil company to fulfill a customer order because the other company’s oil was closer to the customer, thereby reducing transportation costs. In exchange, Sunoco would sell the same amount of oil to the other company in a different location.

A divided New York Tax Appeals Tribunal panel ruled in 2024 that these transactions were exchanges of inventory and not ...