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FIRST CHICAGO CORP. v. C.I.R.

No. 83-2267.

742 F.2d 1102 (1984)

FIRST CHICAGO CORPORATION, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided September 4, 1984.

Attorney(s) appearing for the Case

John L. Snyder, Hopkins & Sutter, Chicago, Ill., for petitioner-appellee.

Ernest J. Brown, U.S. Dept. of Justice, Tax Div., Appellate Sect., Washington, D.C., for defendant-appellant.

Before CUMMINGS, Chief Judge, CUDAHY, Circuit Judge, and FAIRCHILD, Senior Circuit Judge.

PER CURIAM.

This appeal involves the question whether the Commissioner's assessment of a deficiency in income taxes of First Chicago Corporation for 1972 was barred by the 3-year statute of limitations contained in Section 6501(a) of the Internal Revenue Code, as the full Tax Court held in an 8 to 5 decision reported in 80 T.C. 648 (1983). We hold that the statute of limitations was not a bar because the exceptions in Sections 6501...

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