Chrysler Corporation v. Commissioner

OPINION

Laro, Judge:

Respondent moves the Court for partial summary judgment. See Rule 121. Respondent determined deficiencies of $593,967, $13,064,705, and $36,102,409 in petitioner’s Federal income taxes for 1983, 1984, and 1985, respectively. The deficiencies are attributable partially to respondent’s determination that petitioner could not in 1995 amend its 1985 tax return to claim for that year a carryover of foreign tax credits which accrued in 1980, 1981, and 1982.

We decide for the first time whether petitioner timely elected under section 901(a) to credit (rather than deduct) its 1980,…