- 2 -
Marjorie A. Burnett, Thomas D. Johnston, Robert L.
Moore II, Michael J. McGoldrick, and Nancy M. Seweryn,
for petitioner.
John A. Guarnieri, Richard H. Gannon, and Keith L.
Gorman, for respondent.
OPINION
WHALEN, Judge: Respondent determined the following
deficiencies in petitioner's Federal income tax:
Year Deficiency
1979 $10,563,157
1981 5,163,449
1983 35,916,359
Petitioner disputes the above deficiencies and further
claims to have overpaid income taxes for 1979, 1981, and
1983 by at least $25,082,591, $6,881,055, and $14,137,211,
respectively.
After concessions, there are three issues for decision
in this case. Each issue will be the subject of a separate
opinion. The issue that is the subject of this opinion
arises in the context of computing the overall limit
imposed by section 904(a) on the foreign tax credits
claimed by petitioner under section 901(a) for taxable
years 1982, 1983, 1984, and 1986, referred to herein as
the years in issue. In this opinion, all section
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