PERKIN-ELMER CORP. & SUBSIDIARIES v. COMMISSIONER

Docket No. 28860-89.

103 T.C. 464 (1994)

THE PERKIN-ELMER CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 28, 1994.


Attorney(s) appearing for the Case

Robert J. Cunningham, James M. O'Brien, and Debra Falduto Novack, for petitioner.

Victoria W. Fernandez, for respondent.


OPINION

TANNENWALD, Judge:

In Perkin-Elmer Corp. v. Commissioner, T.C. Memo. 1993-414, we decided, after trial, a severed issue under section 482.1 A second issue, involving section 902, has been conceded by petitioner. The sole issue left for consideration is whether section 1.861-8(e)(3)(ii), Income Tax Regs., validly apportions research...

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