Legal Opinion

First Chicago Corp. v. Commissioner

United States Tax Court

Decided March 24, 1987No. Docket No. 38229-84Published

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

First Chicago Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

First Chicago Corp. v. Commissioner

Docket No. 38229-84

United States Tax Court

88 T.C. 663; 1987 U.S. Tax Ct. LEXIS 36; 88 T.C. No. 37;

March 24, 1987. March 24, 1987, Filed

Decision will be entered for the petitioner.

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…

2Cases cited16 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

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