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COMPAQ COMPUTER CORP. AND SUBSIDIARIES v. C.I.R.

No. 00-60648.

277 F.3d 778 (2001)

COMPAQ COMPUTER CORPORATION AND SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

December 28, 2001.

Attorney(s) appearing for the Case

Mark A. Oates (argued), Thomas V.M. Linguanti, Robert S. Walton, Baker & McKenzie, Chicago, IL, Allen Duane Webber, Baker & McKenzie, Washington, DC, John M. Peterson, Baker & McKenzie, Palo Alto, CA, for Petitioner-Appellant.

Thomas James Sawyer (argued), Richard Bradshaw Farber, U.S. Dept. of Justice, Tax Div., Charles Casazza, Clerk, U.S. Tax Court, Richard W. Skillman Chief Counsel, IRS, Claire Fallon, Acting Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for CIR.

Before JONES, SMITH, and DeMOSS, Circuit Judges.

EDITH H. JONES, Circuit Judge:

In this case, Compaq Computer Corporation engaged in a foreign stock transaction involving the purchase and resale of American Depository Receipts (ADRs). The Tax Court held that because the ADR transaction lacked economic substance, the transaction should be disregarded for federal income tax purposes. 113 T.C. 214, 1999 WL 735238 (1999). The Eighth Circuit recently decided the same question and concluded...

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