T.C. Memo. 2001-189
UNITED STATES TAX COURT
CHICAGO MERCANTILE EXCHANGE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8984-95, 16082-95. Filed July 24, 2001.
Dennis E. Frisby, for petitioner.
Robert M. Ratchford and Dana E. Hundrieser, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case was submitted to the Court without
trial under Rule 122. Respondent determined deficiencies of
$1,706,000, $2,725,835, and $444,347 in petitioner’s Federal
income tax for 1988, 1989, and 1990, respectively. We must
decide whether petitioner is entitled to investment tax credits
that it claims under the transition rules contained in section
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