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INTEL CORP. AND CONSOL. SUBSIDIARIES v. C.I.R.

Nos. 94-70105, 94-70158.

67 F.3d 1445 (1995)

INTEL CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner-Appellee-Cross-Appellant, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellant-Cross-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 16, 1995.

Attorney(s) appearing for the Case

Wayne S. Kaplan argued the case. With him on brief were Joel V. Williamson, Roger J. Jones, and Patricia Anne Haming, Mayer, Brown & Platt, Chicago, Illinois, and James P. Fuller and Catherine L. Curtiss, Fenwick & West, Palo Alto, California, for petitioner-appellee-cross-appellant.

Frank P. Cihlar, Gary R. Allen, Tax Division, United States Department of Justice, Washington, D.C., for the respondent-appellant-cross-appellee.

Before: SNEED, KOZINSKI, and NOONAN, Circuit Judges.

SNEED, Circuit Judge:

The Commissioner of Internal Revenue sought recovery of taxes from Intel Corporation and Consolidated Subsidiaries ("Intel") for the years 1978 through 1980 in the respective amounts of $4,660,900, $6,539,152, and $24,676,625. Intel timely filed its petition in the Tax Court on September 19, 1989.

Settlement negotiations disposed of some issues, but others were unresolved. After a recomputation...

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