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FORD MOTOR CO. v. COMMISSIONER

Docket No. 14949-91.

102 T.C. 87 (1994)

FORD MOTOR COMPANY AND AFFILIATED COMPANIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 31, 1994.

Attorney(s) appearing for the Case

John S. Nolan, Loren M. Opper, and Monika D. Hajek, for petitioners.

Reid M. Huey and Nancy B. Herbert, for respondent.

OPINION

WELLS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the 1970 taxable year in the amount of $3,300,151. Petitioners are hereinafter collectively referred to as petitioner. The deficiency is based on respondent's disallowance of a portion of the deductions claimed by petitioner with respect to obligations it incurred under "structured settlements" it reached in 19801 with tort...

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