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CHRYSLER CORPORATION v. COMMISSIONER

Docket No. 22148-97.

82 T.C.M. 580 (2001)

T.C. Memo. 2001-244

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 September 18, 2001.

Attorney(s) appearing for the Case

James P. Fuller, Ronald B. Schrotenboer, William F. Colgin, Kenneth B. Clark, Jennifer L. Fuller, and Laura K. Zeigler, Auburn Hills, MI, for the petitioner. Nancy B. Herbert and John E. Budde, for the respondent.

MEMORANDUM OPINION

LARO, Judge.

Respondent moves the Court for partial summary judgment. See Rule 121.1 Respondent determined deficiencies of $593,967, $13,064,705, and $36,102,409 in petitioner's 1983, 1984, and 1985 Federal income taxes, respectively. Following our disposition of two other issues in this case, see Chrysler Corp. v. Commissioner [Dec. 54,387], 116 T.C. 465 (2001); Chrysler Corp. v. Commissioner

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