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COMPAQ COMPUTER CORP. & SUBS. v. COMMISSIONER

Docket No. 24238-96.

113 T.C. 214 (1999)

COMPAQ COMPUTER CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

Filed September 21, 1999.

Attorney(s) appearing for the Case

Mark A. Oates, John M. Peterson, Jr., James M. O'Brien, Owen P. Martikan, Paul E. Schick, Robert S. Walton, Tamara L. Frantzen, Erika S. Schechter, A. Duane Webber, David A. Waimon, Lafayette G. Harter III, and Steven M. Surdell, for petitioner.

Dennis M. Kelly, Ginny Y. Chung, and Rebecca I. Rosenberg, for respondent.

COHEN, Chief Judge:

The issues addressed in this opinion are whether petitioner's purchase and resale of American Depository Receipts (ADR's) in 1992 lacked economic substance and whether petitioner is liable for an accuracy-related penalty pursuant to section 6662(a). (In a separate opinion, Compaq Computer Corp. & Subs. v. Commissioner, T.C. Memo. 1999-220, we held that income relating to printed circuit assemblies...

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