ELECT. ARTS, INC. v. COMMISSIONER

Docket Nos. 2433-99, 2434-99.

118 T.C. 226 (2002)

118 T.C. No. 13

ELECTRONIC ARTS, INC. AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ELECTRONIC ARTS PUERTO RICO, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 22, 2002.


Attorney(s) appearing for the Case

A. Duane Webber and Andrew P. Crousore, for petitioners.

Michael R. Cooper, William R. Davis, Jr., Gregory M. Hahn, and Virginia L. Hamilton, for respondent.


OPINION

CHABOT, Judge:

The instant cases are before us on petitioners' motion under Rule 1211 for partial summary judgment that petitioner Electronic Arts Puerto Rico, Inc. (hereinafter sometimes referred to as EAPR), is entitled to possessions tax credits under section 9362 for the years in issue computed using the "profit split method".

Respondent...

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