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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.
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