SUNDSTRAND CORP. v. C.I.R.

No. 93-2250.

17 F.3d 965 (1994)

SUNDSTRAND CORPORATION, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 22, 1994.

Rehearing and Suggestion for Rehearing Denied April 8, 1994.


Attorney(s) appearing for the Case

Francis D. Morrissey, James M. O'Brien, Baker & McKenzie, Chicago, IL, John C. Klotsche (argued), Robert H. Albaral, Owen P. Martikan, Neil D. Traubenberg, Baker & McKenzie, Dallas, TX, for petitioners-appellants.

Gary R. Allen, Bruce R. Ellisen, Frank P. Cihlar (argued), Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for respondent-appellee.

Before POSNER, Chief Judge, ROVNER, Circuit Judge, and MIHM, District Judge.


Rehearing and Suggestion for Rehearing En Banc Denied April 8, 1994.

POSNER, Chief Judge.

Ordinarily when a taxpayer repays money that he had previously received as income and included in his gross income in the year of receipt, he can deduct the payment from his current income in figuring his current income tax liability but he cannot go back and recompute his tax liability for the year in which he received the money that he is now repaying. Money received...

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