- 2 - Penalty Taxable Year Ended Deficiency Sec. 6662(a) Nov. 30, 1991 $42,422,470 -- Nov. 30, 1992 33,533,968 $547,619 The issue addressed in this opinion is whether income relating to printed circuit assemblies (PCA's) should be reallocated under section 482 to petitioner from its Singapore subsidiary for its 1991 and 1992 fiscal years. (A separate opinion will address issues, previously tried and briefed, of whether petitioner's purchase and resale of American Depository Receipts in 1992 lacked economic substance and whether petitioner is liable for an accuracy-related penalty pursuant to section 6662(a). Petitioner has also filed a Motion for Summary Judgment on the issue of whether petitioner is entitled to foreign tax credits for certain United Kingdom Advance Corporation Tax payments.) Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Compaq Computer Corporation is a Delaware corporation with its principal place of business in Houston, Texas. Compaq Computer Corporation and subsidiaries filed consolidated Federal income tax returns for the taxable years ended November 30, 1991,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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