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CONTINENTAL ILLINOIS CORPORATION v. COMMISSIONER

Docket Nos. 5931-83, 35465-86.

55 T.C.M. 1325 (1988)

T.C. Memo. 1988-318

Continental Illinois Corporation v. Commissioner. Citizens and Southern Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed July 26, 1988.

Attorney(s) appearing for the Case

Edward C. Rustigan, 190 South LaSalle Street, Chicago, Ill., Joel V. Williamson, Thomas C. Durham, and Roger J. Jones, for the petitioners. Cynthia J. Mattson and Grace Perez-Navarro, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

These cases involve deficiencies in the income taxes of two separate, affiliated groups of corporations. Both cases involve, among other matters, petitioners' entitlement to foreign tax credit for Brazilian taxes withheld on interest income received as a result of their loans to Brazilian borrowers. Pursuant to joint motions, the Brazilian foreign tax credit issue1 was severed...

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