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ILLINOIS POWER CO. v. C.I.R.

No. 85-1960.

792 F.2d 683 (1986)

ILLINOIS POWER COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 6, 1986.

Attorney(s) appearing for the Case

Edward C. Rustigan, Mayer, Brown & Platt, Chicago, Ill., for petitioner-appellant.

William A. Whitledge, Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before POSNER and FLAUM, Circuit Judges, and ESCHBACH, Senior Circuit Judge.

POSNER, Circuit Judge.

Illinois Power Company asks us to reverse a decision of the Tax Court assessing a deficiency in the company's 1975 federal income taxes of $7 million and a deficiency in its 1976 federal income taxes of $0.6 million. 83 T.C. 842 (1984). The assessment for 1975 relates to investment tax credit, the assessment for 1976 to certain receipts that the government characterizes as income. Although the issues raised by...

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