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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.
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