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COMPUTERVISION CORP. v. C.I.R.

No. 98-1637.

164 F.3d 73 (1999)

COMPUTERVISION CORPORATION AND SUBSIDIARIES, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, First Circuit.

Decided January 7, 1999.

Attorney(s) appearing for the Case

David English Carmack, Attorney, Tax Division, Department of Justice, with whom Loretta C. Argrett, Assistant Attorney General, and Pamela C. Berry, Attorney, Tax Division, Department of Justice, were on brief for respondent-appellant.

John S. Brown with whom George P. Mair, Donald-Bruce Abrams, Matthew D. Schnall and Bingham Dana LLP were on brief for petitioners-appellees.

Before BOUDIN, Circuit Judge, GIBSON, Senior Circuit Judge, and LIPEZ, Circuit Judge.

BOUDIN, Circuit Judge.

Computervision Corporation ("Computervision") is a domestic corporation that designs, manufactures and sells computer-aided design and computer-aided manufacturing products. During the period at issue in this case, Computervision owned Computervision International Corporation ("Computervision International"), which was a sales agent for Computervision and qualified as a domestic international sales corporation ("DISC") under the Internal Revenue...

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