CHRYSLER CORP. v. COMMISSIONER OF INTERNAL REVENUE
United States Tax Court
P's 1980, 1981, and 1982 Federal income tax returns claimed deductions for foreign tax liabilities which had accrued during those years. On July 24, 1995, P amended those returns to elect foreign tax credits in lieu of the deductions and amended its 1985 return to claim a refund from a carryover of the foreign taxes to 1985. R disallowed the claim, determining in relevant part that P's change of the deductions to credits was untimely under sec. 901(a), I.R.C.
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P's 1980, 1981, and 1982 Federal income tax returns claimed deductions for foreign tax liabilities which had accrued during those years. On July 24, 1995, P amended those returns to elect foreign tax credits in lieu of the deductions and amended its 1985 return to claim a refund from a carryover of the foreign taxes to 1985. R disallowed the claim, determining in relevant part that P's change of the deductions to credits was untimely under sec. 901(a), I.R.C. HELD: P's election to credit the foreign taxes was untimely under sec. 901(a), I.R.C. The period specified therein commenced on the due…
1Opinion of the Court
CHRYSLER CORPORATION, F.K.A. CHRYSLER HOLDING CORPORATION, AS SUCCESSOR BY MERGER TO CHRYSLER MOTORS CORPORATION AND ITS CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
CHRYSLER CORP. v. COMMISSIONER OF INTERNAL REVENUE
No. 22148-97
United States Tax Court
116 T.C. 465; 2001 U.S. Tax Ct. LEXIS 31; 116 T.C. No. 30; 81 T.C.M. (CCH) 4124;
June 29, 2001, Filed
Chrysler Corp. v. Commissioner, T.C. Memo 2000-283, 2000 Tax Ct. Memo LEXIS 332 (T.C., 2000)
An appropriate order will be issued granting respondent's motion for partial summary judgment.
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2Cases cited4 opinions
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- Allatt v. United StatesUnited States Court of Claims · 1979
- Chrysler Corp. v. CommissionerUnited States Tax Court · 2000
- CHRYSLER CORP. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001