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OPINION
CHABOT, Judge: The instant cases are before us on
petitioners’ motion under Rule 1211 for partial summary judgment
that petitioner Electronic Arts Puerto Rico, Inc. (hereinafter
sometimes referred to as EAPR), is entitled to possessions tax
credits under section 9362 for the years in issue computed using
the “profit split method”.
Respondent determined deficiencies in corporate income tax
against petitioner Electronic Arts, Inc. and Subsidiaries
(hereinafter sometimes referred to as EA) and against petitioner
EAPR, as follows:
Fiscal Year1 EA EAPR
1993 $121,795 $1,977,045
1994 1,239,846 2,959,550
1995 7,000,775 2,646,755
1 Taxable years ending March 31 of each of the years in issue.
References in this opinion to either petitioner’s fiscal years
are to that petitioner’s taxable year ending March 31 of the
indicated years. Fiscal 1996 is involved as to EA because of a
net operating loss carryback from fiscal 1996 to fiscal 1993.
Petitioners claim overpayments as follows:
1Unless indicated otherwise, all Rule references are to the
Tax Court Rules of Practice and Procedure.
2Unless indicated otherwise, all section references are to
sections of the Code as in effect for the years in issue, and all
Code references are to the Internal Revenue Code of 1986.
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Last modified: May 25, 2011