- 2 - MEMORANDUM OPINION LARO, Judge: Respondent moves the Court for partial summary judgment. See Rule 121.1 Respondent determined deficiencies of $593,967, $13,064,705, and $36,102,409 in petitioner’s 1983, 1984, and 1985 Federal income taxes, respectively. Following our disposition of two other issues in this case, see Chrysler Corp. v. Commissioner, 116 T.C. 465 (2001); Chrysler Corp. v. Commissioner, T.C. Memo. 2000-283, we must decide whether Chrysler Corporation (Chrysler) may deduct for 1985 amounts it paid to redeem its common stock held in the employee stock ownership trust (ESOT) underlying the Chrysler Employee Stock Ownership Plan (ESOP). We hold it may not. Background Our statement of the background of this case is derived mainly from the pleadings, the parties’ stipulation of facts as to the instant issue, the exhibits attached to that stipulation of facts, the parties’ respective memoranda filed on May 3, 2000, as to issues of fact and law in this case, and the materials filed as to the instant motion. We also include within our statement, as they relate to the operation of the ESOP and ESOT, the pertinent provisions of the Chrysler Corporation Loan 1 Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the relevant years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011