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manufactured in Puerto Rico, and (b) whether EAPR’s
activities constituted the manufacture of the video
games in Puerto Rico by EAPR “within the meaning of
subsection (d)(1)(A) of section 954”, as required by
section 936(h)(5)(B)(ii) (final flush). (This issue
affects only the EAPR docket, 2434-99.)
Our statements as to the facts are based entirely on the
parties’ stipulations of facts and exhibits, those matters that
are admitted in the pleadings, those matters that are admitted in
the motion papers, and those matters set forth in affidavits
submitted by the parties.
I. Background
A. The Petitioners
When the respective petitions were filed in the instant
cases, both EA and EAPR were Delaware corporations with their
principal corporate offices in Redwood City, California. (EA was
incorporated in Delaware in September 1991; its predecessor was
incorporated in California in 1982.) For the years in issue,
both EA and EAPR kept their books and filed their income tax
returns on the basis of an accrual method of accounting and a
fiscal year ending March 31.
During the years in issue, EA developed, manufactured (or
had manufactured), marketed, and distributed interactive
entertainment software for a variety of entertainment systems,
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