- 2 - John B. Magee and Richard C. Stark, for petitioner. Theodore J. Kletnick, for respondent. OPINION WELLS, Chief Judge: This matter is before the Court on a Joint Application to Perpetuate Testimony Before Commencement of a Case (joint application), filed May 7, 2001. Unless otherwise indicated, section references are to sections of the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure. GlaxoSmithKline Holdings (Americas), Inc. (Glaxo), and the Commissioner of Internal Revenue (the Commissioner) filed a joint application, pursuant to Rule 82, to take the depositions of two of Glaxo’s former executives. For convenience, we will refer to Glaxo and the Commissioner, collectively, as the applicants. Glaxo has no current petition for redetermination of deficiencies before the Court. Background Glaxo is a holding company for a global pharmaceutical business headquartered in the United Kingdom. In 1992, the Commissioner began an examination of Glaxo’s tax returns for 1989 and 1990. The Glaxo examination currently encompasses Glaxo’s tax returns for the years 1989 through 1999.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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