Business Notes BANKRUPTCIES

After settling an epic four-year legal battle last month by agreeing to pay Pennzoil $3 billion, Texaco seemed ready to emerge from bankruptcy proceedings, and the company's executives thought they had every reason to celebrate. But the men who wear the star may have to put away the champagne and bring back the lawyers. Last week the Internal Revenue Service told Texaco that it may face a stunning back-tax bill: $6.5 billion.

According to Texaco lawyers, the IRS claim relates largely to the company's oil dealings between 1979 and 1981. As a member of a consortium known as the Arabian American Oil Co. (Aramco), Texaco bought crude from Saudi Arabia for $28 per bbl., even though the official going rate was $32 per bbl. The IRS appears to be saying that Texaco should have considered the $4-per-bbl. price break to be income and paid taxes on it. The other members of Aramco -- Exxon, Chevron and Mobil -- could also face penalties, but they have not heard from the taxman yet.

The IRS's novel interpretation of the tax laws has not been tested in the courts. The agency apparently indicated the maximum possible penalty in order to meet a Jan. 22 deadline set by a U.S. bankruptcy judge for making claims against Texaco, and it may ultimately reduce the amount of back taxes it is seeking.