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tax credits pursuant to section 901(a) for certain U.K. advance
corporation tax (ACT) payments.3
Summary judgment may be granted if the pleadings and other
materials demonstrate that no genuine issue exists as to any
material fact and that a decision may be rendered as a matter of
law. See Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C.
518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). The record
shows and the parties do not dispute that there is no genuine
issue as to any material fact. Accordingly, we may render
judgment on the issue in the instant case as a matter of law.
See Rule 121(b).
Background
Petitioner is a Delaware corporation with its principal
place of business in Houston, Texas. Petitioner owns 100 percent
of the issued and outstanding stock of Compaq Computer Group,
Ltd. (Compaq U.K.), a corporation organized and existing under
the laws of the United Kingdom. Compaq U.K. owns 100 percent of
the issued and outstanding stock of Compaq Computer
Manufacturing, Ltd. (CCML), and Compaq Computer, Ltd. (CCL)
(hereinafter we will sometimes refer to CCML and CCL collectively
3 The ACT was first introduced by the Finance Act, 1972. The
Income and Corporation Taxes Act, 1988, which was in effect
during the year in issue, made only minor changes with respect to
the ACT. The ACT was abolished, effective for distributions
after Apr. 1, 1999, by the Finance Act, 1998, sec. 31.
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