- 2 -
S1 and S2 and used by them against their U.K. tax is
not a subsidy within the meaning of I.R.C. sec. 901(i).
Mark A. Oates, John M. Peterson, Jr., James M. O'Brien, Owen
P. Martikan, Paul E. Schick, Robert S. Walton, Tamara L.
Frantzen, Erika S. Schechter, Allen Duane Webber, David A.
Waimon, Lafayette G. Harter, III, and Steven M. Surdell, for
petitioners.
Allan E. Lang, Sandra K. Robertson, and Barbara A. Felker,
for respondent.
OPINION
WELLS, Judge: In the instant case, the parties filed cross-
motions for summary judgment pursuant to Rule 121(a).1 The
issue2 presented by the parties' summary judgment motions is
whether Compaq Computer Corp. (petitioner) is entitled to foreign
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1992, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2 The instant case involves several issues for which the
parties filed separate briefs. In an opinion issued July 2,
1999, we addressed the issue of whether income relating to
printed circuit assemblies should be reallocated under sec. 482
to petitioner from its Singapore subsidiary for its 1991 and 1992
fiscal years. See Compaq Computer Corp. & Subs. v. Commissioner,
T.C. Memo. 1999-220. In an opinion issued Sept. 21, 1999, we
addressed the issue of whether a foreign tax credit resulting
from certain ADR transactions should be allowed. See Compaq
Computer Corp. & Subs. v. Commissioner, 113 T.C. __ (1999).
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