- 2 - James P. Fuller, Ronald B. Schrotenboer, Kenneth B. Clark, William F. Colgin, and Barton W.S. Bassett, for petitioner. Jeffrey L. Bassin, Nancy B. Herbert, and Bethany A. Ingwalson, for respondent. 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, 1981, and 1982 foreign taxes.1 We hold it did not. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. 1 The parties also dispute whether petitioner timely claimed a refund under sec. 6511(d)(3)(A). On the basis of our holding on the issue before us, we need not decide that dispute.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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