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SEAGATE TECHNOLOGY, INC. v. COMMISSIONER

Docket No. 15086-98.

80 T.C.M. 759 (2000)

T.C. Memo. 2000-361

Seagate Technology, Inc., Successor In Interest To Seagate Peripherals, Inc., f/k/a Conner Peripherals, Inc. v. Commissioner.

United States Tax Court.

Filed November 27, 2000.

Attorney(s) appearing for the Case

Mark A. Oates, Thomas V.M. Linguanti, John M. Peterson, Jr., Mary E. Wynne, and Andrew P. Crousore, for the petitioner. Debra K. Estrem, Michael J. Cooper, Bryce A. Kranzthor, Jeffrey L. Heinkel, Lavonne D. Lawson, Ewan D. Purkiss, and Mark S. Heroux, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

Pursuant to Rule 121,1 this matter is before the Court on the parties' cross-motions for partial summary judgment.2 The parties seek to determine, as a matter of law, whether the "relation-back doctrine" established in Arrowsmith v. Commissioner [52-2 USTC ¶ 9527], 344 U.S. 6 (1952), applies in characterizing petitioner...

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