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FIRST CHICAGO CORP. v. COMMISSIONER

Docket No. 11174-87.

96 T.C. 421 (1991)

FIRST CHICAGO CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 7, 1991.

Attorney(s) appearing for the Case

John L. Snyder, Paul S. Caselton, Marilyn D. Franson, and Francis O. McDermott, for the petitioner.

Beth L. Williams and Michael L. Boman, for the respondent.

GERBER, Judge:

Respondent, in a notice of deficiency dated February 4, 1987, determined a $3,993,041 deficiency in petitioner's 1983 corporate income tax. The issue considered in this opinion concerns petitioner's foreign tax credit.1 In conjunction with respondent's 1983 determination, petitioner's taxable years 1978 through 1982 have some bearing on this issue because of the effect of the foreign tax credit carryover from those...

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