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SUN MICROSYSTEMS, INC. v. COMMISSIONER

Docket No. 8976-91.

69 T.C.M. 1884 (1995)

T.C. Memo. 1995-69

Sun Microsystems, Inc. and Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed February 13, 1995.

Attorney(s) appearing for the Case

Frederick R. Chilton, Jr., and Ronald B. Schrotenboer, San Francisco, Calif., for the petitioner.

Steven A. Wilson, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

In Sun Microsystems, Inc. v. Commissioner [Dec. 49,327(M)], T.C. Memo. 1993-467, we decided a severed issue relating to stock warrants. Thereafter, a stipulation of settled issues was filed, reflecting mutual concessions, leaving as the sole issue remaining for decision whether the term "wages", for purposes of the credit for increasing research activities in section 41,

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