COMPAQ COMPUTER CORP. v. COMMISSIONER

Docket No. 24238-96.

113 T.C. 363 (1999)

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

United States Tax Court.

Filed November 18, 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, Allen Duane Webber, David A. Waimon, Lafayette G. Harter III, and Steven M. Surdell, for petitioners.

Allan E. Lang, Sandra K. Robertson, and Barbara A. Felker, for respondent.


OPINION

WELLS, Judge:

In the instant case, the parties filed cross-motions for summary judgment pursuant to Rule 121(a).1 The issue2 presented by the parties' summary judgment motions is whether Compaq Computer Corp. (petitioner) is entitled to foreign tax credits pursuant to section 901(a) for certain U.K. advance corporation tax (ACT) payments.

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