Vimpelcom, one of the few Russian companies with shares listed on the New York Stock Exchange, said it had paid its taxes in full and will contest the claim, which is preliminary and still needs to be confirmed before it becomes legally enforceable.

But coming after a flurry of mounting back-tax bills have driven Yukos, the country's largest oil company and a favorite of foreign investors, to the verge of bankruptcy, the Vimpelcom news crystallized fears that other big companies may come under pressure from the government. On the Big Board, Vimpelcom shares fell 22% to $30.10.

"If the state is sanctioning fishing expeditions by the tax authorities on profitable companies and requisitioning some of those profits for the state, it would be nothing short of a catastrophe," said Martin Taylor, manager at Thames River Capital, a London hedge fund that owns stock in Vimpelcom. "It would mean no company in Russia was safe."

Though there have been a number of high-profile foreign investments in Russia in recent months, the Yukos case has shaken confidence, investors say. Lee Raymond, chairman and chief executive of ExxonMobil Corp., which once was interested in buying a stake in Yukos, said in a television interview on PBS's "The Charlie Rose Show" Tuesday that his view in 2003 that Russia was becoming a safe place to invest "was somewhat premature."

"I think it's going to be pretty difficult for people to think about putting large sums of money in as investment" until the Russian government makes clear what its policy on natural resources is, he added.

The Vimpelcom tax bill could signal that the campaign against Yukos and its founder Mikhail Khodorkovsky, currently on trial for fraud and tax evasion, now could expand to other "oligarchs" -- the tycoons who amassed huge fortunes in the 1990s. Vimpelcom's principal shareholder, Alfa Group, is headed by Mikhail Fridman, a billionaire who also is joint shareholder in TNK-BP, a Russian joint venture that includes BP PLC. In recent weeks, other major oil companies have been hit with back-tax claims, but none nearly as large as the $26 billion bill Yukos faces.

Nonetheless, the target of the latest attack has surprised many observers. Unlike Yukos, Vimpelcom is untainted by the controversial privatizations that have dogged Russia's energy sector during the past 10 years. Listed on the Big Board since 1996 and partly owned by Norway's Telenor ASA, it long has been seen as a model of good corporate governance in a market where opaque ownership and abuses of shareholder rights still are common.

"It's obviously going to raise some additional questions," a senior U.S. diplomat said of the tax claim. "Vimpelcom is a very solid company."

Analysts said Vimpelcom's tax issue likely had little in common with the crackdown on Yukos and is more likely related to a conflict between Alfa Group and rivals in the Russian telecommunications sector over control of OAO Megafon, the country's No. 3 wireless carrier in terms of subscribers. Earlier this year, Vimpelcom faced licensing and other administrative problems that analysts linked to the bitter dispute. The company so far has managed to resolve them without any substantial impact on its business.

"This is not part of some grand campaign inspired by the top leadership, which is obviously the case in the Yukos affair," said Christopher Granville of United Financial Group, a Moscow brokerage house.

Nonetheless, the Vimpelcom tax claim overshadowed the positive news yesterday that President Vladimir Putin had reiterated his commitment to liberalizing the electricity sector during the next two years. That closely watched reform had been one of several major restructuring efforts that appeared to stall in recent months, fueling fears that Mr. Putin was veering away from the liberal economic policies of his first term.

In a statement, Vimpelcom said tax inspectors, reviewing its 2001 tax filing, had concluded it owed an additional 2.5 billion rubles in tax plus an extra 1.9 billion rubles in fines and penalties. The tax claim -- amounting to nearly a fifth of Vimpelcom's total revenue in 2001 -- relates to Vimpelcom's relations with KB Impuls, a subsidiary that holds its Moscow license. Mikhail Umarov, a Vimpelcom spokesman, said tax authorities claim the company was trying to minimize profit tax by redistributing revenue between Vimpelcom and KB Impuls. "We don't agree with that," he said.

Last year, Russian telecommunications regulators told Vimpelcom to merge all its subsidiaries and consolidate all its licenses under one umbrella, in part to make it easier to tax the company. It recently completed a merger with Vimpelcom-R, which held its regional licenses, and was planning to do the same with KB Impuls.

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