Reuters today reports that whatever the outcome of a two-day hearing scheduled to start in Houston tomorrow, Russian tax collectors are expected to press on with carving up Yukos and selling its assets to recover US$27.5 billion in alleged back taxes.

Yukos' owners have promised the buyers "a lifetime of litigation", starting with suits against the Russian Federation, Rosneft, Russian gas monopoly Gazprom and Germany's Deutsche Bank, among others.

Yukos said it was suing Baikal Finance Group, Rosneft, Gazprom and former Gazprom unit Gazpromneft for more than US$20 billion for their alleged part in the sale of its key production unit, Yuganskneftegaz, that was on-sold to government-owned oil firm Rosneft for US$9.4 billion.

The Russian plaintiffs are demanding the cases be thrown out, saying the links to Houston - home to a Yukos executive and to bank accounts containing some US$27 million - do not justify using the court to challenge Russia's sovereign will.

Lawyers say that the complexity of the case and the lack of precedent will make it a hard call for Houston Bankruptcy Court Judge Letitia Clark.

But analysts say whichever way the decision goes, Russia will eventually prevail in its battle against Yukos, whose main owner, Mikhail Khodorkovsky, is facing a possible 10-year jail sentence in his trial for fraud and tax evasion.

"I don't think they can rule that the US court has jurisdiction over actions of the Russian Government," Alfa Bank analyst Anna Boutenko said. "It's only a matter of time."

Analysts also see Rosneft as the likely future home of Yukos' other smaller operating units, Samaraneftegaz and Tomsknef, which could be crucial pawns in the drive to liberalise the world's biggest gas firm, Gazprom, which foreign investors cannot currently invest in directly.