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FIRST CHICAGO CORPORATION v. COMMISSIONER

Docket No. 11174-87.

61 T.C.M. 1774 (1991)

T.C. Memo. 1991-44

First Chicago Corporation v. Commissioner.

United States Tax Court.

Filed February 5, 1991.

Attorney(s) appearing for the Case

John Lindsey Snyder and Marilyn D. Franson, Three First Natl. Plaza, Chicago, Ill., for the petitioner. Beth L. Williams and Michael Boman, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency of $3,933,041 in petitioner's Federal income tax for 1983.

The matter considered herein (which was severed from the other matters in the case) concerns petitioner's entitlement to foreign tax credits for Brazilian withholding taxes on interest income received by petitioner's principal subsidiary, First National Bank of Chicago (FNBC), on net loans made to Brazilian...

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