- 6 - was filed. It was the common parent of an affiliated group of corporations, which filed consolidated Forms 1120, U.S. Corporation Income Tax Return, for 1987, 1988, 1989, 1990, and 1991. During the years in issue, petitioner conducted its business through several operating groups: Systems software, applications software, systems peripherals and accessories group, OEM sales, U.S. sales and marketing, international operations, and press. Approximately three-quarters of petitioner’s worldwide employees were based in Redmond, where petitioner developed its products. B. MS-FSC MS-FSC was organized as a Virgin Islands corporation on December 24, 1984. On January 1, 1985, petitioner and MS-FSC entered into a Commission and Expense Agreement, which remained in effect during the years in issue. At all relevant times, MS-FSC elected to be taxed as a foreign sales corporation and was so qualified. MS-FSC determined its commission income using section 925(a) administrative pricing rules. C. Petitioner’s Products Petitioner’s first products were programming languages and tools that permitted software developers to create computer software. Thereafter, petitioner’s product line was expanded to include operating systems. In 1981, petitioner released its first operating system, “Microsoft Disk Operating System” or “MS-DOS”,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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