Legal Opinion

First Chicago Corp. v. Commissioner

United States Tax Court

Decided March 24, 1987No. Docket No. 38229-84PublishedCited by 55 opinions

In both 1980 and 1981, T's taxable income was reduced by items of tax preference. In each year, T's tax liability on its taxable income, as reduced by the preferences, was fully satisfied by foreign and investment tax credits generated that year. If the taxable income in each year had not been reduced by the preferences, the resulting tax payable on that income would nonetheless still have been fully satisfied by foreign and investment tax credits generated that year.

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In both 1980 and 1981, T's taxable income was reduced by items of tax preference. In each year, T's tax liability on its taxable income, as reduced by the preferences, was fully satisfied by foreign and investment tax credits generated that year. If the taxable income in each year had not been reduced by the preferences, the resulting tax payable on that income would nonetheless still have been fully satisfied by foreign and investment tax credits generated that year. The preferences, by reducing T's taxable income, allowed an increased amount of foreign tax credits to go unused in the years…

1Opinion of the Court

OPINION

RAUM, Judge:

The Commissioner determined deficiencies against petitioner and “Affiliated Corporations” in the amounts of $1,261,807 for 1980 and $2,246,809 for 1981.1 While the notice of deficiency makes numerous adjustments to the taxable income of petitioner and subsidiaries of petitioner, the deficiency is entirely in minimum tax and the sole issue raised in this case is whether petitioner is liable in the foregoing amounts for the minimum tax on tax preferences under section 56, I.R.C. 1954, for the years 1980 and 1981. Petitioner does not dispute the adjustments and computations in…

2Cases cited15 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Bingler v. JohnsonSupreme Court of the United States · 1969
  4. Brewster v. GageSupreme Court of the United States · 1930
  5. Rowan Cos. v. United StatesSupreme Court of the United States · 1981

10 more not listed; retrieve them via the Exa API.

3Cited by55 opinions

  1. Allen v. Comm'rUnited States Tax Court · 2002
  2. Segel v. CommissionerUnited States Tax Court · 1987
  3. Zinniel v. CommissionerUnited States Tax Court · 1987
  4. First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
  5. Estate of Wallace v. CommissionerUnited States Tax Court · 1990

50 more not listed; retrieve them via the Exa API.

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