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MICROSOFT CORPORATION v. COMMISSIONER

Docket No. 16878-96.

75 T.C.M. 1747 (1998)

T.C. Memo. 1998-54

Microsoft Corporation v. Commissioner.

United States Tax Court.

Filed February 10, 1998.

Attorney(s) appearing for the Case

Michael P. Boyle, Redmond, Wash., James M. O'Brien, and John M. Peterson, for the petitioner. Beth L. Williams, William A. McCarthy, David P. Fuller, and John M. Altman, for the respondent.

MEMORANDUM OPINION

JACOBS, Judge:

This matter is before the Court on the parties' cross-motions for partial summary judgment. Both motions were filed pursuant to Rule 121.1

The issue presented by these motions is whether respondent is barred by the expiration of the statutory period of limitations from recalculating the amount of petitioner's affiliated group's combined taxable income under the section 936(h) profit-split...

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