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APPLE COMPUTER, INC. v. COMMISSIONER

Docket No. 34127-87.

98 T.C. 232 (1992)

APPLE COMPUTER, INC. AND CONSOLIDATED SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 3, 1992.

Attorney(s) appearing for the Case

Glenn A. Smith, William W. Koopman, and Eric D. Ryan, for petitioner.

William E. Bonano and Mary E. Wynne, for respondent.

OPINION

JACOBS, Judge:

Respondent determined deficiencies in the consolidated income tax of Apple Computer, Inc. and Consolidated Subsidiaries for their 1981, 1982, and 1983 fiscal years. The parties filed cross-motions for partial summary judgment pursuant to Rule 121.1 Summary judgment is appropriate if the pleadings and other materials show that there is no genuine issue as to any material fact and a decision may be...

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