ILL. TOOL WORKS, INC., & SUBS. v. COMMISSIONER

Docket No. 16022-99.

117 T.C. 39 (2001)

117 T.C. No. 4

ILLINOIS TOOL WORKS, INC. & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 2001.


Attorney(s) appearing for the Case

James P. Fuller, Jennifer L. Fuller, Laura K. Zeigler, William F. Colgin, Jr., and Kenneth B. Clark, for petitioner.

Rogelio A. Villageliu, for respondent.


COHEN, Judge:

Respondent determined deficiencies of $2,370,750 and $818,812, respectively, in petitioner's consolidated Federal income tax for 1992 and 1993.

After concessions, the issue for decision is whether $6,956,590 of a payment made by petitioner in satisfaction of a court judgment, based on a patent infringement claim that was brought against an acquired corporation and assumed as a contingent liability...

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