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FORD MOTOR CO. v. C.I.R.

No. 94-1956.

71 F.3d 209 (1995)

FORD MOTOR COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 5, 1995.

Rehearing and Suggestion for Rehearing Denied February 13, 1996.

Attorney(s) appearing for the Case

John S. Nolan, Mark Lewis Evans (briefed), Alan I. Horowitz (argued and briefed), Miller & Chevalier, Washington, DC, Monika D. Hajek, Loren M. Opper, Ford Motor Co., Office of General Counsel, Dearborn, MI, for petitioner-appellant.

David L. Jordan, I.R.S., Office of Chief Counsel, Washington, DC, Gary R. Allen, Acting Chief (briefed), Richard Farber, Steven W. Parks (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, for respondent-appellee.

Before: ENGEL, MILBURN, and NORRIS, Circuit Judges.

Rehearing and Suggestion for Rehearing En Banc Denied February 13, 1996.

MILBURN, Circuit Judge.

Petitioner Ford Motor Company ("Ford") appeals the decision of the United States Tax Court upholding respondent Commissioner of Internal Revenue's ("Commissioner") reduction of petitioner's deductions for its obligations under agreements it entered into in settlement of tort lawsuits against it. On appeal, the issue is...

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