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

No. 87-2028.

842 F.2d 180 (1988)

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

United States Court of Appeals, Seventh Circuit.

Decided March 16, 1988.

Attorney(s) appearing for the Case

Teresa E. McLaughlin, Dept. of Justice, Washington, D.C., for respondent-appellant.

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

Before BAUER, Chief Judge, POSNER, Circuit Judge, and WILL, Senior District Judge.

POSNER, Circuit Judge.

The government appeals from a decision by the Tax Court, 88 T.C. 663, holding that there is no minimum tax on tax-preference items until the items confer an actual benefit on the taxpayer. The facts are simple, their legal significance elusive.

In 1980 and 1981, First Chicago Corporation, the parent of the First National Bank of Chicago, had taxable income of $21 million and $39 million (we are rounding...

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