Chrysler Corporation - Page 3




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                                     Background                                       
               All facts were stipulated.  The parties’ stipulation of                
          facts and the exhibits submitted therewith are incorporated                 
          herein by this reference.  The stipulated facts are found                   
          accordingly.  Petitioner’s principal place of business was in               
          Auburn Hills, Michigan, when the petition was filed.  Petitioner            
          is an accrual basis taxpayer that reports its income and expenses           
          on the basis of the calendar year.                                          
               Petitioner timely filed its 1980 through 1985 Federal income           
          tax returns on or about September 15 of the appropriate years.              
          Petitioner deducted on its 1980 through 1983 returns its foreign            
          taxes that accrued during those years.  Petitioner claimed as a             
          credit on its 1984 and 1985 returns its foreign taxes that                  
          accrued during those years.  Petitioner reported the information            
          shown in appendix A on its 1980 through 1985 returns, as                    
          originally filed.                                                           
               On July 24, 1995, petitioner amended its 1980 through 1985             
          returns.  On that date, the period of limitation for assessment,            
          credit, or refund was closed for 1980, 1981, and 1982 and open              
          for 1983, 1984, and 1985.  On each of the 1980 through 1983                 
          amended returns, petitioner claimed a credit for its accrued                
          foreign taxes, rather than the deduction it had reported                    
          originally.  Petitioner’s 1980 through 1985 amended returns                 
          disclose the information summarized in appendix B.                          






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