Compaq Computer Corporation and Subsidiaries - Page 47

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          Conclusion                                                                  
               Petitioner has satisfied its burden of proving that the                
          prices in the intercompany transactions were consistent with                
          arm's-length prices.                                                        
               Our holdings in this opinion will be incorporated into the             
          decision to be entered in this case when all other issues are               
          resolved.                                                                   

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