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BRUNSWICK CORP. v. COMMISSIONER

Docket No. 37357-87.

100 T.C. 6 (1993)

BRUNSWICK CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 11, 1993.

Attorney(s) appearing for the Case

Wayne S. Kaplan and Barry Alan Van Dyke, for petitioner.

Beth L. Williams, Pamela V. Gibson, and William G. Merkle, for respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1980, 1981, and 1982 of $1,098,354, $10,604,917, and $14,531,731, respectively.

The issue for decision is the amount of foreign taxes that petitioner should be deemed to have paid under section 9021 for purposes of determining the foreign tax credit.

This case was submitted fully stipulated...

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