109 T.C. No. 1
UNITED STATES TAX COURT
BANKAMERICA CORPORATION, as successor in interest to CONTINENTAL
BANK CORPORATION, as successor in interest to CONTINENTAL
ILLINOIS CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL
REVENUE, Respondent%
Docket No. 5931-83. Filed July 15, 1997.
P had deficiencies in its Federal income tax for
years 1 and 2. In year 3, P carried back an amount of
investment tax credit to years 1 and 2, reducing the
% This Court has issued five opinions under this docket
number, each captioned Continental Illinois Corp. v.
Commissioner: T.C. Memo. 1988-318, T.C. Memo. 1989-468, T.C.
Memo. 1989-636, 94 T.C. 165 (1990), and T.C. Memo. 1991-66,
relating to the tax liability of petitioner's predecessor for the
tax years 1975 through 1979. Portions of the decisions in T.C.
Memo. 1988-318, T.C. Memo. 1989-636, and T.C. Memo. 1991-66 were
affirmed in part and reversed in part and remanded to this Court
in Continental Illinois Corp. v. Commissioner, 998 F.2d 513 (7th
Cir. 1993), cert. denied 510 U.S. 1041 (1994), and a decision was
entered in accordance with the opinion of the Court of Appeals
for the Seventh Circuit. Petitioner has filed a timely motion to
redetermine interest.
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