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SEAGATE TECHNOLOGY, INC. v. COMMISSIONER

Docket No. 15086-98.

80 T.C.M. 912 (2000)

T.C. Memo. 2000-388

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

United States Tax Court.

Filed December 22, 2000.

Attorney(s) appearing for the Case

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

MEMORANDUM OPINION

GERBER, Judge:

Petitioner moved for partial summary judgment1 concerning what has been denominated the "section 4822 stock option cost-sharing issue". In particular, petitioner questions whether respondent may employ section 482 to make an allocation to include petitioner's cost, if any, of employee stock options in the cost-sharing pool for purposes of a cost-sharing agreement...

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