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CHRYSLER CORPORATION v. COMMISSIONER

Docket No. 22148-97.

80 T.C.M. 334 (2000)

T.C. Memo. 2000-283

Chrysler Corporation, f/k/a Chrysler Holding Corporation, As Successor By Merger to Chrysler Motors Corporation and Its Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed August 31, 2000.

Attorney(s) appearing for the Case

James P. Fuller, Two Palo Alto Sq., Palo Alto, California, Ronald B. Schrotenboer, Kenneth B. Clark, James C. Garahan, and Laura K. Zeigler, for the petitioner. Robin L. Herrell and Nancy B. Herbert, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Respondent moves the Court for partial summary judgment. See Rule 121.1 Respondent determined deficiencies in petitioner's 1983, 1984, and 1985 Federal income taxes in the amounts of $593,967, $13,064,705 and $36,102,409, respectively. In relevant part, respondent determined that petitioner could not accrue a deduction of its estimated lifetime warranty expenses, or a part thereof, for vehicles...

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