- 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 sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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