116 T.C. No. 30
UNITED STATES TAX 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
Docket No. 22148-97. Filed June 29, 2001.
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 dates of the
returns for 1980, 1981, and 1982, the years for which P
elected the foreign tax credit.
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